United States Office of Water (4303) EPA-821-R-97-016
Environmental Protection October 1997
Agency
ERA, National Emission Standards for
Hazardous Air Pollutants;
Proposed Standards for Hazardous
Air Pollutants from Chemical
Recovery Combustion Sources at
Kraft, Soda, Sulfite, and Stand-Alone
Semichemical Pulp Mills
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U. S. ENVIRONMENTAL PROTECTION AGENCY
40 CFR Part 63
[AD-FRL- ]
/ , -
NATIONAL EMISSION STANDARDS FOR HAZARDOUS AIR POLLUTANTS;
PROPOSED STANDARDS FOR HAZARDOUS AIR POLLUTANTS FROM
CHEMICAL RECOVERY COMBUSTION SOURCES AT KRAFT, SODA,
SULFITE, AND STAND-ALONE SEMICHEMICAL PULP MILLS
AGENCY: Environmental Protection Agency (EPA)
ACTION: Proposed Rule and Notice of Public Hearing
SUMMARY: This action proposes national emission standards
for hazardous air pollutants (NESHAP) for the pulp and paper
production source category under section 112 of the Clean
Air Act as amended (CAA). The proposed standards focus on
reducing hazardous air pollutants (HAP's) from new and
existing sources used in chemical recovery processes at
kraft, soda, sulfite, and stand-alone semichemical pulp
mills. The intent of the proposed standards is to protect
the public health and the environment by reducing HAP
emissions to the level corresponding to the maximum
achievable control technology (MACT). The proposed
standards would reduce HAP emissions by about •
2,600 megagrams per year (Mg/yr) (2,800 tons per year
[tons/yr]). In addition, emissions of criteria pollutants
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such as particulate matter (PM) and volatile organic
compounds (VOC's) would be reduced by about 56,400 Mg/yr
(62,100 tons/yr).
DATES: Comments. The EPA will accept written comments on
the proposed rule until [insert 60 days after publication in
the FEDERAL REGISTER].
Public Hearing. If requested, EPA will hold a public
hearing concerning the proposed rule beginning at 10 a.m. on
[contact Ms. Cathy Coats at (919) 541-5422 for date, to be
inserted in the FEDERAL REGISTER notice] at the EPA Office
of Administration Auditorium, Research Triangle Park, North
Carolina. Requests to present oral testimony must be made
by [insert date 3 weeks after publication in the FEDERAL
REGISTER]. These requests should be submitted to Ms. Cathy
Coats, Minerals and Inorganic Chemicals Group (MD-13),
Emission Standards Division, U. S. Environmental
Protection Agency, Research Triangle Park, NC 27711,
telephone number (919) 541-5422. Persons interested in
attending the hearing should call Ms. Coats to verify that a
hearing will be held.
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ADDRESSES: Comments. Interested parties may submit written
comments (in duplicate, if possible) to Public Docket
No. A-94-67 at the following address: U. S. Environmental
Protection Agency, Air and Radiation Docket and Information
Center, 401 M Street, SW., Washington, D.C. 20460. The EPA
requests that a separate copy of the comments also be sent
to the' contact person listed below in the "FOR FURTHER
INFORMATION CONTACT" section.
Comments may also be submitted electronically by,
sending electronic mail (.e-mail) to: a-and-r-
docket@epamail.epa.gov. Electronic comments must be
submitted as an ASCII file avoiding the use of special
characters and any form of encryption. Comments will also
be accepted on diskette in WordPerfect 5.1 or ASCII file
format. All comments in electronic form must be identified
by the docket No. A-94-67. No confidential business
information should be submitted through e-mail. Electronic
comments may be filed online at many Federal Depository
Libraries.
Docket. The docket (No. A-94-67) is available for
public inspection and copying from 8:30 a.m. to noon and
from 1 to 3 p.m., Monday through Friday at EPA's Air and
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Radiation Docket and Information Center, Waterside Mall,
Room M-1500 (ground floor), 401 M Street, SW., Washington,
B.C. 20460. The following documents and other supporting
materials related to this rulemaking are available for
review in the docket center: Technical Support Document:
Chemical Recovery Combustion Sources at Kraft and Soda Pulp
Mills (docket No. II-A-31); Technical Support Document:
Chemical Recovery Combustion Sources at Sulfite Pulp Mills
(docket No. II-A-28) ; Profile of U.S. Stand-Alone
Semichemical Pulp Mills Memo (docket No. II-B-70);
Nationwide Baseline HAP Emissions for Combustion Sources at
Stand-Alone Semichemical Pulp Mills Memo (docket No. II-B-
67); Nationwide Costs, Environmental Impacts and Cost-
Effectiveness of HAP Control Options for Combustion Sources
at Stand-Alone Semichemical Mills Memo (docket No. II-B-69);
the Nationwide Costs, Environmental Impacts, and Cost-
Effectiveness of Regulatory Alternatives for Kraft, Soda,
Sulfite, and Semichemical Combustion Sources Memo (docket
No. II-B-63); the Economic Analysis for the National
Emission Standards for Hazardous Air Pollutants for Source
Category: Pulp and Paper Production; Effluent Limitations
Guidelines, Pretreatment Standards, and New Source
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Performance Standards: Pulp, Paper, and Paperboard
Category--Phase I (docket No. II-A-32); the State of
Washington PM Data for Kraft Recovery Furnaces, Smelt
Dissolving Tanks, and Lime Kilns Memo (docket No. II-B-59);
and the State of Washington PM Data for Sulfite Combustion
Units Memo (docket No. II-B-40). Also, copies of this
information may be obtained from the Air Docket upon request
by calling (202) 260-7548 or sending a FAX to
(202) 260-4000. A reasonable fee may be charged for copies
of docket materials.
The preamble and the regulatory text for this proposed
NESHAP for chemical recovery combustion sources at kraft,
soda, sulfite, and stand-alone semichemical pulp mills also
are available on the Technology Transfer Network (TTN), one
of EPA's electronic bulletin boards. The TTN provides a
forum for technological and regulatory exchange in various
areas of air pollution_ control. The service is free, except
for the cost of a phone call. Dial (919) 541-5742 for up to
a 14,400 baud rate modem. If more information on the TTN is
needed, call the TTN help line at (919) 541-5384.
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FOR FURTHER INFORMATION CONTACT: Mr. Jeff Telander,
Minerals and Inorganic Chemicals Group, Emissions Standards
Division (MD-13) , U. S. Environmental Protection Agency,
Research Triangle Park, North Carolina 27711, telephone
number (919) 541-5427.
SUPPLEMENTARY INFORMATION: Regulated entities. Entities
potentially regulated by this proposed rule are those kraft,
soda, sulfite, and stand-alone semichemical pulp mills with
chemical recovery processes that involve the combustion of
spent pulping liquor. Regulated categories and entities are
listed below in Table 1.
TABLE 1. REGULATED CATEGORIES AND ENTITIES
Category
Examples of regulated entities
Industry
kraft pulp mills
soda pulp mills
sulfite pulp mills
stand-alone semichemical pulp
mills
Table 1 is not intended to be exhaustive, but rather
provides a guide for readers regarding entities likely to
regulated by this action. Table 1 lists the types of
entities that EPA is now aware could potentially be
regulated by this action. Other types of entities not
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listed in the table could also be regulated. To determine
whether your facility is regulated by this action, you
should carefully examine the applicability criteria in
§ 63.860. If you have questions regarding the applicability
of this action to a particular entity, consult the person
listed in the preceding "FOR FURTHER INFORMATION CONTACT"
section.
The information presented in the remainder of this
preamble is organized as follows:
I. „ Statutory Authority
II. Introduction
A. Background
B. NESHAP for source categories
C. Health Effects of Pollutants
D. Industry Profile
III. Summary of Proposed Standards
A. Applicability
. B. Emission Limits and Requirements
1. PM HAP Standards for Kraft and Soda Pulp
Mills
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2. Total Gaseous Organic HAP Standards for Kraft
and Soda Pulp Mills
3. PM Standards for Sulfite Pulp Mills
4. Total Gaseous Organic HAP Standards for
Stand-Alone Semichemical Pulp Mills
C. Performance Test Requirements
D. Monitoring Requirements and Compliance Provisions
E. Recordkeeping- and Reporting Requirements
IV. Rationale
A. Selection of Source Category
B. Selection of Emission Points
1. Emission Points--Kraft Pulp Mills
2. Emission Points--Soda Pulp Mills
3. Emission Points--Sulfite Pulp Mills
4. Emission Points--Stand-Alone Semichemical
Pulp Mills
C. Selection of Definition of Affected Source
D. Selection of Pollutants
1. PM HAP's
2. Total Gaseous Organic HAP's
• 3. Hydrochloric Acid (HC1)
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E. Determination of Subcategories and MACT Floors
1. MACT Floors--Kraft and Soda Pulp Mills
2. MACT Floors--Sulfite Pulp Mills
3. MACT Floors--Stand-Alone Semichemical Pulp
Mills
F. Discussion of Regulatory Alternatives
1. Kraft and Soda Pulp Mills
2. Sulfite Pulp Mills
3. . Stand-Alone Semichemical Pulp Mills
G. Selection of Proposed Standards for Existing and
New Sources
1. Existing Sources
2. New Sources
H. Selection of Format of the Standards
1. PM HAP Standards for Kraft and Soda Pulp
Mills
2. PM Standards for Sulfite Pulp Mills
3. Total Gaseous Organic HAP Standard for Kraft
and Soda Pulp Mills
4. Total Gaseous Organic HAP Standard for Stand-
Alone Semichemical Pulp Mills
I. Selection of Monitoring Requirements
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J. Selection of Test Methods
K. Selection of Reporting and Recordkeeping
Requirements
L. Relationship to other Regulations
1. Noncombustion Source Rule and Chemical
Recovery Combustion Source Rule
2. NSPS (subpart BE of part 60) and Chemical
Recovery Combustion Source Rule
3. New Source Review/Prevention of Significant
Deterioration Applicability
M. Solicitation of Comments
V. Impacts of Proposed Standards
A. Number of Impacted Sources
B. Environmental Impacts
C. Energy Impacts
D. Cost Impacts
E. Economic Impacts
F. Benefits' Analysis
VI. Administrative Requirements
A. Docket
B. Public Hearing
C. Executive Order 12866
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D. Enhancing the Interdepartmental Partnership Under
Executive Order 12875
E. Unfunded Mandates Reform Act
F. Regulatory Flexibility
G. Paperwork Reduction Act
. H. Clean Air Act
I. Statutory Authority
The statutory authority for this proposal is provided
by sections. 101, 112, 114, 116, and 301 of the Clean Air ••
Act, as amended (42 U.S.C. 7401, 74,12, 7414, 7416, and
7601)
II. Introduction
A. Background
On February 23, 1978, EPA promulgated new source
performance standards (NSPS) to limit emissions of PM and
total reduced sulfur (TRS) compounds from new, modified, and
reconstructed kraft pulp mills under authority of .
section 111 of the Act (43 FR 7568). In addition, EPA
issued retrofit guidelines in 1979 for control of TRS
emissions at existing kraft pulp mills not subject to the
NSPS. The NSPS for kraft pulp mills limit TRS emissions
from recovery furnaces, smelt dissolving tanks (SDT's), lime
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kilns, digesters, multiple effect evaporators, black liquor
oxidation (BLO) systems, brownstock washers, and condensate
strippers that were constructed, modified, or reconstructed
after September 24, 1976. The standards also limit PM
emissions from recovery furnaces, SDT's, and lime kilns that
were constructed, modified, or reconstructed after
September 24, 1976. As required under section 111(a) of the
Act, these standards reflected the application of the best
technological system of continuous emission reduction that
the Administrator determined had been adequately
demonstrated (taking into consideration the cost of
achieving such emission reduction, and any nonair quality
health and environmental impacts and energy requirements).
Revisions to these standards were promulgated on
May 20, 1986 (51 PR 18538). The revisions exempted BLO
systems from the TRS standards; revised the existing TRS
limit and format of the standard for SDT's; deleted .the
requirement to monitor the combustion temperature in lime
kilns, power boilers, and recovery furnaces; changed the
frequency of excess emission reports from quarterly to
semiannually; and exempted diffusion washers from the TRS
standard for brownstock washers. The revisions also
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required that monitored emissions be recorded and specified
the conditions [§ 60.284(e)] under which.excess emissions
would not be deemed a violation of § 60.11(d). Today's
action,does not revise or change the TRS requirements of the
NSPS. However, today's standards do include PM emission
limits, as a surrogate for measuring PM HAP emissions, for
combustion sources (existing and new) in the chemical
recovery area of the mill.
On December 17, 1993, EPA proposed (1) effluent
limitations guidelines and standards for the control of
wastewater pollutants for the pulp and paper industry and
(2) NESHAP for noncombustion sources in the pulp and paper
industry (58 FR 66078), otherwise referred to as "MACT I."
The emission points covered in the proposed NESHAP for
noncombustion sources were limited to process units in the
pulping and bleaching processes (e.g., digesters, bleaching
towers, and associated tanks) and in the associated
wastewater collection and treatment systems at mills that
chemically pulp wood fiber using kraft, sulfite, soda, or
semichemical methods. In March 1996, EPA proposed to
include for regulation additional noncombustion operations
and mills not covered under the December 17, 1993 proposal
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(e.g., mechanical pulping, pulping of secondary fiber by
nonchetnical means, nonwood pulping, and paper machines) ,
otherwise referred to as "MACT III" (61 FR 9383). The
NESHAP for noncombustion sources and the effluent guidelines
are being promulgated as part of today's integrated rule,
"NESHAP for Source Category: Pulp and Paper Production;
Effluent Limitations Guidelines, Pretreatment Standards, and
New Source Performance Standards: Pulp, Paper, and
Paperboard Category." This proposed NESHAP for chemical
recovery combustion sources at kraft, soda, sulfite and
stand-alone semichemical pulp mills, otherwise referred to
as "MACT II," does not revise or change the requirements of
the NESHAP for noncombustion sources that is being
promulgated today.
B. NESHAP for Source Categories
Section 112 of the Act provides a list of 189 HAP's and
directs EPA to develop rules to control HAP emissions from
both new and existing major sources. The Act requires that
the rules be established by categories of emission sources
considering all HAP's emitted, rather than establishing
rules based on the emission of a single pollutant from a
source category. The statute also requires that the
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standards reflect the maximum degree of reduction in
emissions of HAP's that is achievable, taking into
consideration the cost of achieving such emission reduction
and any nonair quality health and environmental impacts and
energy requirements. This level of control is commonly
referred to as MACT.
In addition, the Act sets out specific criteria to be
considered for establishing a minimum level of control and
criteria (incremental cost, energy impacts, etc.) for '
evaluating control options more stringent than the minimum
level of control. This minimum level of control is commonly
referred to as the MACT "floor." The MACT floor for new
sources, as specified by the Act, is "the emission control
that is achieved in practice by the best controlled similar
source." The MACT floor for existing sources, as specified
by the Act, is the average emission limitation achieved by
the best performing 12 percent of existing. sources in each '
category or subcategory of 30 or more sources (CAA
section 112(d)(3)). For smaller categories or
subcategories, the Act specifies that standards shall not be
less stringent than the average emission limitation achieved
by the best performing five sources in the category or
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subcategory. These floor determinations are based on data
available to the Administrator at the time the standards are
developed. The statutory provisions do not limit how the
standard is set, beyond requiring that it be applicable to
all sources in a category or subcategory and at least as
stringent as the MACT floor. The emission standards are to
be reviewed and revised as necessary no less often than
every 8 years. Also, EPA may later promulgate more
stringent standards to address any unacceptable health or
environmental risk that remains after the imposition of
controls resulting from today's standards (CAA
section 112 (f)) .
C. Health Effects of Pollutants
The Clean Air Act was created in part "to protect and
enhance the quality of the nation's air resources so as to
promote the public health and welfare and the productive
capacity of its population" (CAA section 101(b)(1)).
Title III of the Act establishes a technology-based control
program to reduce stationary source emissions of HAP's. The
goal of section 112(d) is to apply such control technology
to reduce emissions and thereby reduce the hazard of HAP's
emitted from stationary sources.
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This proposed rule is technology-based (i.e., based on
MACT) . The MACT strategy avoids' dependence on a risk-based
approach as a pre-requisite for regulating air toxics. Such
risk assessments are limited by incomplete information on
what HAP's are emitted, what level of emissions is
occurring, what health and safety benchmarks are available
to assess risk, what health effects may be caused by certain
pollutants, and how best to model these effects, among other
things. Because of these issues, a quantitative risk
assessment of potential effects from all of the HAP's
emitted from pulp and paper combustion sources is not
included in this rulemaking. However, as described in
section IV.D.B.d of this preamble, an exposure assessment .
was conducted to determine if current emissions of hydrogen
chloride (HCl) from pulp and paper combustion sources result
in exposures that provide an ample margin of safety.
The EPA does recognize that the degree of adverse
effects to health can range from mild to severe. The extent
and degree to which health effects may be experienced is
dependent upon (1) ambient concentrations observed in the
area, (2) duration of exposures, and (3) characteristics of
exposed individuals (e.g., genetics, age, pre-existing
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health conditions, and lifestyle) which vary significantly
with the population. Some of these factors are also
influenced by source-specific characteristics (e.g.,
emission rates and local meteorological conditions) as well
as pollutant-specific characteristics.
Available emission data, collected during development
of this proposed rule, show that metals, various organic
compounds, and HC1 are the most significant HAP's emitted
from pulp and paper combustion sources. Following is a
summary of the potential health and environmental effects
associated with exposures, at some level, to these emitted
pollutants.
Almost all metals appearing on the section 112(b) list
are emitted from pulp and paper combustion sources. These
metals can cause a range of effects, including mucous
membrane effects (e.g., bronchitis, decreased,lung
function), gastrointestinal effects, nervous system
disorders (from cognitive effects to coma or even death),
skin irritation, and reproductive and developmental
disorders. Additionally, several of the metals accumulate
in the environment and in the human body. Cadmium, for
example, is a cumulative pollutant that can cause kidney
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effects after cessation of exposure. Similarly, the onset
of effects from beryllium exposure may be delayed by months
to years. Further, some of the metal compounds have been
classified by EPA as known (e.g., arsenic and chromium (VI))
or probable (e.g., cadmium and beryllium) human carcinogens.
All forms of mercury, a volatile metal, may be
characterized as quite toxic, with different health effects
associated with different forms of the pollutant. Methyl
mercury is the most toxic form of mercury to which humans
and wildlife generally are exposed. Exposure to methyl
mercury occurs primarily through the aquatic food chain.
The target organ for methyl mercury toxicity in humans is
the nervous system. The range of neurotoxic effects can
vary from subtle decrements in motor skills and sensory
ability to tremors, inability to walk, convulsions, and
death. Exposure to inorganic mercury is associated with
renal impairment. Some forms of mercury have also been
classified as possible human carcinogens. Exposure to
mercury compounds can also cause effects in plants, birds,
and nonhuman mammals. Reproductive effects are the primary
concern for avian mercury poisoning.
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Organic compounds emitted from pulp and paper
combustion sources include acetaldehyde, benzene,
formaldehyde, methyl ethyl ketone, methyl isobutyl ketone,
methanol, phenol, styrene, toluene, and xylenes. These
organic compounds have a range of potential health effects
associated with exposure at some level. Some of the effects
associated with short-term inhalation exposure to these
pollutants are similar and include irritation of the eyes,
skin, and respiratory tract in humans; central nervous
system effects (e.g., drowsiness, dizziness, headaches,
depression, nausea, irregular heartbeat); reproductive and
developmental effects; and neurological effects. Exposure
to benzene and methyl isobutyl ketone at extremely high
concentrations may lead to respiratory paralysis, coma, or
death. Human health effects associated with long-term
inhalation exposure to the organic compounds listed above
may include mild symptoms such as nausea, headache,
weakness, insomnia, intestinal pain, and burning eyes;
effects on the central nervous system; disorders of the
blood; toxicity to the immune system; reproductive disorders
in women (e.g., increased risk of spontaneous abortion);
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developmental effects; gastrointestinal irritation; liver
injury; and muscular effects.
In addition to the noncancer effects described above,
some of the organic HAP's emitted from pulp and paper
combustion sources have been classified by EPA as either
known (e.g., benzene) or probable (e.g., acetaldehyde and
formaldehyde) human .carcinogens.
Hydrogen chloride is an inorganic HAP which is highly
corrosive to the eyes, skin, and mucous membranes. Short-
term inhalation of HC1 by humans may cause coughing,
hoarseness, inflammation and ulceration of the respiratory
tract, as well as chest pain and pulmonary edema if exposure
exceeds threshold concentrations. Long-term occupational
exposure of humans to HCl has been reported to cause
inflammation of the stomach, skin, and lungs, and
photosensitizatibh.
The health and environmental effects associated with
exposure to PM and ozone are described in EPA's Criteria
Documents, which support the national ambient air quality
standards (EPA 1996, "Air Quality Criteria for Ozone and
Related Photochemical Oxidants," EPA-600/P-93-004, RTP, NC;
EPA 1996, "Air Quality Criteria for Particulate Matter,"
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EPA-600/P-95-001, RTP, NC). Briefly, PM emissions have been
associated with aggravation of existing respiratory and
cardiovascular disease and increased risk of premature
death. Volatile organic compounds are precursors to the
formation of ozone in the ambient air. At ambient levels,
human laboratory and community studies have shown that ozone
is responsible for the reduction of lung function,
respiratory symptoms (e.g., cough, chest pain, throat and
nose irritation), increased hospital admissions for
respiratory causes, and increased lung inflammation. Animal
studies have shown increased susceptibility to respiratory
infection and lung structure changes.
Studies have shown that exposure to ozone can cause
foliar injury and disrupt carbohydrate production and
distribution in plants. The reduction in carbohydrate
production and allocation can lead to reduced root growth,
reduced biomass or yield production, reduced plant vigor
(which can increase susceptibility to attack from insects
and disease and damage from cold), and diminished ability to
successfully compete with more tolerant species. These
effects have been observed in native vegetation in natural
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ecosystems and in a selected number of commercial trees and
' f. • •
agricultural crops.
D. Industry Profile
There are currently 122 kraft, 2 soda, 15 sulfite, and
14 stand-alone semichemical pulp mills in the United States.
The majority (52 percent) of kraft mills are located in the
Southeastern United States. The two soda pulp mills are
located in Tennessee and Pennsylvania; The majority of
sulfite mills.(67 percent) are located in Washington and
Wisconsin. Half of all stand-alone semichemical pulp mills
are located in the Midwestern United States.
The kraft process is the dominant pulping process in
the United States. The kraft and soda processes account for
approximately 82 percent of all domestic pulp production;
sulfite and stand-alone semichemical processes account for
approximately 2 and 6 percent of the domestic pulp
production, respectively.-
Numerous HAP compounds are emitted from combustion
sources in the chemical recovery area at kraft,' soda,
sulfite, and stand-alone semichemical pulp mills. The HAP
compounds emitted in the largest quantities are methanol and
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HC1. Methanol and HCl account for approximately 70 percent
of the total HAP's emitted from the chemical recovery area.
All of the kraft, soda, sulfite, and stand-alone
semichemical pulp mills are believed to be major HAP
emission sources (i.e., emissions greater than or equal to
9.1 Mg/yr [10 tons/yr] for an individual HAP or 23 Mg/yr
[25 tons/yr] for total HAP's). In most cases, HAP emissions
from combustion sources in the chemical recovery area alone
are sufficient to characterize these mills as major sources.
III. Summary of Proposed Standards
A. Applicability
The proposed standards apply to all existing and new
kraft, soda, sulfite, and stand-alone semichemical pulp
mills with chemical recovery processes that involve the
combustion of spent pulping liquor. Specifically, the
sources that are regulated by today's proposed standards are
(1) nondirect contact evaporator (NDCE) recovery furnaces,
direct contact evaporator (DCE) recovery furnace systems,
SDT's, and lime kilns at kraft and soda pulp mills,-
(2) sulfite combustion units at sulfite pulp mills; and
(3) semichemical combustion units at stand-alone
semichemical pulp mills.
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All existing kraft. and soda pulp mills have chemical
recovery processes that involve the combustion of spent
pulping liquor. However, several existing sulfite and
stand-alone semichemical pulp mills do not recover pulping
chemicals by combusting spent liquor. Three of the
15 sulfite mills use a calcium-based sulfite process and do
not have chemical recovery combustion units and, thus, would
not be impacted by this proposed rule. One of the 14 stand-
alone semichemical pulp mills burns spent liquor in a power
boiler and does not have chemical recovery; therefore, that
mill also would not be impacted by this proposed rule.
B. Emission Limits and Requirements
Today's proposed standards would regulate PM HAP
emissions and/or total gaseous organic HAP emissions for
chemical recovery combustion sources in the pulp and paper
source category. The proposed emission standards are
summarized in Table 2.
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Hazardous air pollutants.are proposed only for existing
recovery furnaces, SDT's, and lime kilns at kraft and soda
pulp_mills. Limits for total gaseous organic HAP emissions
are proposed for new kraft and soda recovery furnaces and
existing and new semichemical combustion units. Either
methanol or total hydrocarbons (THC), depending on the
subcategory, is used as a surrogate for total gaseous
organic HAP emissions. The emission standards for each
subcategory are discussed in the following sections by the
pollutant regulated.
1. PM HAP Standards for Kraft and Soda Pulp Mills
Today's rule proposes PM HAP emission limits for
existing recovery furnaces, SDT's, and lime kilns at kraft
and soda pulp mills. In addition, PM emission limits are
proposed as a surrogate for PM HAP emission limits for both
new and existing affected sources at kraft and soda pulp
mills. The EPA is using the term "PM HAP" in this preamble
to refer to the standards which can be measured either on a
total-PM basis or on a HAP component of PM basis. For
existing kraft and soda recovery furnaces, SDT's, and gas-
fired lime kilns, the proposed PM emission limits are the
same as the New Source Performance Standards for Kraft Pulp
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Mills (43' FR 7568) . Under today's proposed standards,
existing oil-fired lime kilns would be subject to a more
stringent PM standard than the NSPS requirements.
The proposed standards also' would allow the use of a
"bubble, compliance alternative" for determining compliance
with the PM HAP standard for existing sources at kraft and
soda pulp mills. The bubble compliance alternative would
allow mills to set PM or PM HAP emission limits for each
existing affected source at the mill such that, if these
limits are met, the total emissions from all existing
affected sources would be less than or equal to a mill-
specific bubble limit. This mill-specific bubble limit is
calculated based on the proposed emission limits (referred
to as reference concentrations or reference emission rates)
for each affected source and mill -specific gas flow rates
and process rates. Equation 1, below, would be used to
calculate the bubble limit based on PM emissions.
ELpM = [(Cref,RF) (QRFtot) + (Cre£,i,K) (QLKtot)] (Fl) / (BLScot) + ERlref,SDT
Eq. (1)
where :
ELPM = overall PM emission limit for all
existing affected sources at the kraft or
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soda pulp mill, kg/Mg (Ib/ton) of black
liquor solids fired.
= reference concentration of 0.10 g/dscm
(0.044 gr/dscf) corrected to 8 percent
oxygen for existing kraft or soda
recovery furnaces.
= sum of the average gas flow rates
measured during the performance test from
all existing recovery furnaces at the
kraft or soda pulp mill, dry standard
cubic meters per minute (dscm/min) (dry
standard cubic feet per minute
[dscf/min]).
cref,LK = reference concentration of 0.15 g/dscm
(0.067 gr/dscf) corrected to 10 percent
oxygen for existing kraft or soda lime
kilns.
= sum of the average gas flow rates
measured during the performance test from
all existing lime kilns at the kraft or
soda pulp mill, dscm/min (dscf/min).
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Fl = conversion factor, 1.44 minutes*
kilogram/day*gram (min»kg/d»g)
(0.206 minutes»pound/day«grain
[min«lb/d«gr] ) .
BLStot = sum of the average black liquor solids
firing rates of all existing recovery
furnaces at the kraft or soda pulp mill
measured during the performance test,
megagrams per day - (Mg/d) (tons per day
[tons/d]) of black liquor solids fired.
ERlref/SDT = reference emission rate of 0.10 kg/Mg
(0.20 Ib/ton) of black liquor solids
fired for existing kraft or soda smelt
dissolving tanks.
Equation 2, below, would be used to calculate the total
bubble limit based on PM HAP emissions.
ELpMHAp = ERref,RF + (ERref,LK) (CaOtot/BLStot) + ER2ref,SDT
Eq. (2)
where:
= overall PM HAP emission limit for all
existing affected sources at the kraft or
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31
soda pulp mill, kg/Mg (Ib/ton) of black
liquor solids fired.
ERref,RF = reference emission rate of .l.OOE-03 kg/Mg
(2.01E-03 Ib/ton) of black liquor solids
fired for existing kraft or soda recovery
furnaces.
ERref,LK = reference emission rate of 6.33E-03 kg/Mg
(1.27E-02 Ib/ton) of CaO produced for
existing kraft or soda lime kilns.
CaOtot = sum of the average lime production rates
for all existing lime kilns at the kraft
or soda pulp mill measured as CaO during
the performance test, Mg CaO/d (ton
CaO/d).
BLStot = sum of average black liquor solids firing
rates of all existing recovery furnaces at
the kraft or soda pulp mill measured
during the performance test, Mg/d (ton/d)
of black liquor solids fired.
ER2ref/SDT = reference emission rate of 6.20E-05 kg/Mg
(1.24E-04 Ib/ton) of black liquor solids
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32
fired for existing kraft or soda smelt
dissolving tanks.
Owners or operators that choose to comply with the PM HAP
standards using the proposed bubble compliance alternative
would be allowed to meet either the PM bubble limit
determined in Equation 1 or the PM HAP bubble limit
determined in Equation 2, but would not be required to meet
both bubble limits. The proposed bubble compliance
alternative would not be applicable to new sources. All new
affected sources at kraft and soda pulp mills would be
required to meet the individual emission limitations set for
those sources. Also, owners or operators of existing
sources subject to the NSPS for kraft pulp mills would be
required to continue to meet the PM emission limits of that
rule, regardless of which option they choose for complying
with today's PM HAP standard.
Owners or operators that choose to comply with the PM
HAP standards using the proposed bubble compliance
alternative would be required to submit preliminary emission
limits to the applicable permitting authority for approval
for each existing kraft or soda recovery furnace, SDT, and
lime kiln at the mill. Before the preliminary PM or PM HAP
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33
emission limits would b£ approved, the owner or operator
would be required to submit documentation demonstrating that
if the preliminary emission limits for each emission source
are met,.the entire group of affected sources would be in
compliance with the mill-wide allowable emission level. The
allowable emission level would be determined from the
applicable bubble equation using the reference
concentrations and reference emission rates for each
emission source and source-specific factors for exhaust gas
flow rates and process rates. Once approved by the
applicable permitting authority, the. emission limits would
be incorporated in the operating permit for the mill.
Thereafter, the owner or operator of the kraft or soda pulp
mill would demonstrate compliance with the standards by
demonstrating that each recovery furnace, SDT, and lime kiln
emitted less than or equal to the approved emission limit
for that source. In addition, the PM emission limits for
any existing recovery furnace, SDT, and lime kiln subject to
the NSPS for kraft pulp mills must be at least as stringent
as the PM emission limits established in the NSPS. An
example of how the bubble compliance alternative can be used
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34
to establish emission limits for affected sources at an
example mill is provided in the docket (Docket No. II-B-75) .
With one exception, owners or operators that choose to
comply with the PM HAP standards using the proposed bubble
compliance alternative must include all existing sources in
the bubble. Any existing affected source that can be
classified as a stand-by unit (i.e., a source that operates
for less than 6,300 hours during any calendar year) could
not be included as part of a bubble. Owners or operators of
stand-by units must accept either the proposed PM or
proposed PM HAP emission limits shown in Table 2 for those
units. The EPA requests comments on the proposal to exclude
stand-by units from the proposed bubble compliance
alternative. Some have argued that stand-by units--
especially units operating less than 20 percent of the
year--may be relatively expensive to control. Thus,
inclusion of stand-by units within a compliance bubble may
yield important cost savings by allowing a more stringent
control of other units to offset the relatively high cost
emissions from the stand-by unit. The EPA also requests
comment on the proposed definition of a stand-by unit as a
unit operating less than 6,300 hours in a calendar year.
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35
2- Total Gaseous Organic HAP Standards for Kraft and
Soda Pulp Mills
There are no standards under the proposed rule for
total gaseous organic HAP's for existing NDCE recovery
furnaces or DCE recovery furnace systems. All new recovery
furnaces at kra'ft and soda pulp mills would be required to
meet a total gaseous organic HAP limit, as measured by
methanol, of 0.012 kg/Mg (0.025 Ib/ton) of black liquor
solids fired.
3. PM Standards for Sulfite Pulp Mills
Existing sulfite combustion units would be required to
meet a PM emission limit of 0.092 g/dscm (0.040 gr/dscf)
corrected to 8 percent oxygen. New sulfite combustion units
would be required to meet a PM emission limit of
0.046 g/dscm (0.020 gr/dscf) corrected to 8 percent oxygen.
4 - Total Gaseous Organic HAP Standards for Stand-Alone
Semichemical Pulp Mills
All existing and new stand-alone semichemical pulp
mills with chemical recovery combustion units would be
required to reduce total gaseous organic HAP emissions
(measured as THC) from these units by 90 percent, or meet a
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36
total gaseous organic HAP emission limit (measured as THC)
of 1.49 kg/Mg (2.97 Ib/ton) of black liquor solids fired.
C. Performance Test Requirements
The following discussion identifies the test methods to
be used for compliance determinations.
Test Method 5, "Determination of Particulate Emissions
from Stationary Sources" [40 CFR part 60, appendix A]--in
conjunction with either the integrated sampling techniques
of Test Method 3, "Gas Analysis for the Determination of Dry
Molecular Weight" [40 CFR part 60, appendix A] or Test
Method 3A, "Determination of Oxygen and Carbon Dioxide
Concentrations in Emissions from Stationary Sources" [40 CFR
part 60, appendix A]--is the test method for determining
compliance with the PM emission standards for new and
existing kraft and soda recovery furnaces, SDT's, and lime
kilns and for new and existing sulfite combustion units.
Test Method 17, "Determination of Particulate Emissions from
Stationary Sources (In-Stack Filtration Method}" may be used
as an alternative to Test Method 5 if a constant value of
0.009 g/dscm (0.004 gr/dscf) is added to the results of Test
Method 17 and the stack temperature is no greater than
205 degrees Centigrade (°C) [400 degrees Fahrenheit (°F)].
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37
Test- Method 29, "Determination of Metals Emissions from
Stationary Sources" [40 CFR part 60, appendix A] is the test
. method for determining compliance•with the PM HAP emission
standards for existing kraft and soda recovery furnaces,
SDT's, and lime kilns. Test Method 29 also may be used as
an alternative to Test Method 5 for measuring PM emissions.
The Agency also will allow operators or owners the option of
measuring all of the PM HAP's (except mercury) with Test
Method 29 and making a separate measurement of the mercury
using Test Method 101A, "Determination of Particulate and
Gaseous Mercury Emissions from Sewage Sludge Incinerators"
[40 CFR part 61, appendix A].
Test Method 308, "Procedure for Determination of
Methanol Emissions from Stationary Sources" is being
promulgated today as part of the final NESHAP for
noncombustion sources at pulp and paper mills and is the
test method for determining compliance with the total
gaseous organic HAP emission limit for new kraft and soda
NDCE recovery furnaces that are not equipped with dry
electrostatic precipitator (ESP) systems and for DCE
recovery furnace systems.
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38
Test Method 25A, "Determination of Total Gaseous
Organic Concentration using a Flame lonization Analyzer"
[40 CFR part 60, appendix A] is the test method for
determining compliance with the total gaseous organic HAP
emission limit for new and existing combustion sources at
stand-alone semichemical pulp mills.
D. Monitoring Requirements and Compliance Provisions
Each owner,or operator of an affected source would be
required to install, operate, calibrate, and maintain a
continuous monitoring system for each affected source. The
owner or operator also would be required to establish a
range of values for each operating parameter (associated
with a process operation or with an emission control device)
to be monitored based upon values recorded during the
initial performance test or during qualifying previous
.performance tests using the required test methods. If
values from previous performance tests are used to establish
the operating parameter range, the owner or operator would
be required to certify that the control devices and
processes had not been modified subsequent to the testing
upon which the data used to establish the operating ranges
were obtained. The owner or operator could conduct multiple
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39
performance tests to establish ranges of operating
parameters. The owner or operator also could establish
expanded or replacement ranges during subsequent performance
tests. An exceedance of the operating parameters would
occur when the measured operating parameter levels, averaged
over a specified time period, are outside the established
range for a predetermined duration. However, with the
exception of opacity exceedances, no more than one
exceedance would be attributed to an affected source during
any given 24-hour period. The following paragraphs describe
(1) the operating parameters to be monitored, (2) the
averaging periods and frequency with which these parameters
should be monitored, (3) when corrective action is required
to return operating parameters to levels that are within the
established range, and (4) when operating parameter
-j
exceedances constitute a violation of the standards.
Owners or operators of existing kraft or soda recovery
furnaces that are equipped with an ESP for PM or PM HAP
control would be required to install, calibrate, maintain,
and operate continuous opacity monitoring systems (COM3).
The COM3 would be required to perform at least one cycle of
sampling and analysis for each successive 10-second period
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40
arid one cycle of data recording for each successive 6-minute
period. If 10 consecutive 6-minute average values of
opacity exceed 20 percent, the owner or operator would be
required to initiate the corrective actions contained in the
mill's startup, shutdown, and malfunction (SSM) plan. A
violation would occur when 6 percent of the 6-minute average
opacity values recorded during any 6-month reporting period
are greater than 35 percent.
Owners or operators of new kraft or soda recovery
furnaces and new or existing kraft or soda lime kilns that
are equipped with ESP's for PM or PM HAP control would also
be. required to install, calibrate, maintain, and operate
COM3. The COM3 would be required to perform at least one
cycle of sampling and analysis for each successive 10-second
period and one cycle of data recording for each successive
6-minute period.. If 10 consecutive 6-minute average values
of opacity are greater than 20 percent, the owner or
operator would be required to initiate the corrective
actions contained in the facility's SSM plan. A violation
would occur when 6 percent of the 6-minute average opacity
values within any 6-month reporting period are greater than
20 percent.
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41
Owners or operators using wet scrubbers to meet the PM
or PM HAP emission limits for any kraft or soda recovery
furnace, smelt dissolving tank, or lime kiln or the PM limit
for sulfite combustion units would be required to install,
calibrate, maintain, and operate a continuous monitoring
system capable of determining, and permanently recording the
pressure drop and scrubbing liquid flow rate at least once
for each successive 15-minute period.- If any 3-hour average
of the pressure drop or scrubbing liquid flow rate falls
outside the established range, the owner or operator would
be required to initiate the corrective actions included in
the facility's SSM plan. A violation would occur when six
3-hour average values of either parameter are outside the
established range during any 6-month reporting period.
Owners or operators using regenerative thermal
oxidizers (RTO's) to comply with the total gaseous organic
HAP emission standard for chemical recovery combustion units
at stand-alone semichemical mills would be required to
establish a minimum RTO operating temperature that indicates
(1) at least a 90 percent reduction in HAP emissions
(measured as THC) or (2) outlet HAP emissions (measured as
THC) of less than or equal to 1.49 kg/Mg (2.97 Ib/ton) of
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42
black liquor solids. To ensure ongoing compliance, the
owner or operator would be required to install, calibrate,
maintain, and operate a monitoring system to measure and
record the RTO operating temperature for each successive
15-minute period. If any 1-hour average of the operating
temperature falls below the minimum established temperature,
the owner or operator would be required to initiate the
corrective actions -contained in the facility's SSM plan. A
violation would occur when any 3-hour average of the RTO
operating temperature falls below the minimum established
temperature.
The owner or operator of an affected source that uses a
wet scrubber, ESP, or RTO to comply with today's standards
may monitor alternative operating parameters subject to
prior written approval by the applicable permitting
authority.
The owner or operator of an affected source that is
complying with today's proposed standards through
operational changes or by a control device other than those
described above would be required to submit a plan proposing
parameters to be monitored, parameter ranges, and monitoring
frequencies to be used to determine ongoing compliance,
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43
subject to approval by the applicable permitting authority.
If any 3-hour .average value of a monitored parameter falls
outside the established range, the owner or operator would
be required to initiate the corrective actions included in
the facility's SSM plan. A violation would occur when six
3-hour average values of a monitored parameter are outside
the established range during any 6-month reporting period.
Owners or operators complying with the total gaseous
organic HAP standard for> new kraft and soda recovery
furnaces through the use of an NDCE recovery furnace
equipped with a dry ESP system would not be required to
perform any continuous parameter monitoring for gaseous
organic HAP's; however, each owner or operator would be
required to maintain onsite a certification statement signed
by a responsible mill official that an NDCE recovery furnace
equipped with a dry ESP system is in use.
E. Recordkeeping ^and Reporting Requirements
In addition to all of the recordkeeping and reporting
requirements outlined in § 63.10 of the General Provisions
(subpart A of 40 CFR part 63), owners or operators of kraft,
soda, sulfite, and stand-alone semichemical pulp mills would
be required to maintain the following records for each
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44
affected source: (1) records of the black liquor solids
firing rates for all recovery furnaces at kraft and soda
pulp mills and spent liquor solids firing rates for all
chemical recovery combustion units at sulfite and stand-
alone semichemical pulp mills; (2) records of the lime
production rates, calculated as CaO, for all kraft and soda
lime kilns; (3) records of all parameter monitoring data;
(4) records and documentation of supporting calculations for
compliance determinations; (5) records of the established
monitoring parameter ranges for each affected source; and
(6) records of all certifications made in order to determine
compliance with the total gaseous organic HAP standards.
All records would have to be maintained for a minimum of
5 years.
IV. Rationale
This section describes the rationale for the decisions
made by the Administrator in determining the proposed MACT
floors for each source category and in selecting the
proposed standards.
A. Selection of Source Category
The list of source categories was published in the
Federal Register on July 16, 1992 and includes pulp and
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45
paper mills as major sources p£ HAP's (57 FR 31576) .
Standards for the pulp and paper production source category
are being developed in phases. In December 1993, EPA
proposed the first set of emission standards for the source
category (i.e., a proposed NESHAP for noncombustion sources
in the pulp and paper industry, otherwise referred to as
MACT I) as part of a "cluster rule" that also included
proposed effluent guidelines and standards for the control
of wastewater pollutants (58 FR 66078). In March 1996, EPA
proposed to include for regulation additional noncombustion
operations and mills not covered under the December 1993
proposal (i.e., MACT III) (61 FR 9383). . The NESHAP for
noncombustion sources, as well as the effluent guidelines
and standards, are being promulgated as part of today's
cluster rule. An additional set of standards for the source
category is covered by today's proposed NESHAP for chemical
recovery combustion sources (i.e., MACT II). Today's
proposed "combustion sources" NESHAP covers (1) combustion
units in the chemical recovery area at kraft, soda, sulfite,
and stand-alone semichemical pulp mills, (2) SDT's at kraft
and soda pulp mills, and (3) BLO systems at kraft pulp
mills. Although kraft and soda SDT's and kraft BLO systems
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46
are not combustion sources, these equipment are included in
today's proposed "combustion sources" NESHAP because they
are closely associated with the chemical recovery combustion
equipment. For the purposes of today's proposed standards,
the combustion units, SDT's, and BLO systems are
collectively referred to as "chemical recovery combustion
sources." Specifically, the chemical recovery combustion
sources are defined as (1) kraft and soda NDCE recovery
furnaces and DCE recovery furnace systems (which include BLO
systems), (2) kraft and soda SDT's, (3) kraft and soda lime
kilns, (4) sulfite combustion units, and (5) semichemical
combustion units.
B. Selection of Emission Points
The following section identifies the HAP emission
points for kraft, soda, sulfite and stand-alone semichemical
pulp mills that were examined by the Agency for control
under the proposed rule. General descriptions of the
chemical recovery process and equipment also are included in
this section. More detailed information on the emission
points and chemical recovery process can be found in the
technical support documents listed under the "ADDRESSES"
section.
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47
1. Emission Points--Kraft Pulp Mills
Emission points at kraft pulp mills that were examined
by.the Agency for control under the proposed standards are
NDCE recovery furnaces and DCE recovery furnace systems,
SDT's, and lime kilns. These emission points are integral
parts of the kraft chemical recovery process, in which
cooking liquor chemicals (i.e., sodium hydroxide [NaOH] and
sodium sulfide [Na2S]) are recovered from spent cooking
liquor. Cooking liquor, which is used in the pulping
process, is commonly referred to as white liquor; spent
cooking liquor is commonly referred to as black liquor.
a. NDCE Recovery Furnaces and DCE Recovery Furnace
Systems. There are an estimated 209 recovery furnaces
operating at U.S. kraft pulp mills. The kraft recovery
furnace is essentially a chemical recovery unit and steam
generator that uses black liquor as its fuel. More
specifically, the kraft recovery furnace (1) recovers
inorganic pulping chemicals from black liquor as smelt by
reducing sodium sulfate (Na2SO4) to Na2S and (2) combusts
organic compounds in black liquor to produce steam for mill
processes.
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48 .
Kraft recovery furnaces can be classified based on the
type of final-stage evaporator used to increase the solids
content of black liquor prior to firing in the furnace. The
final-stage evaporator, which follows the multiple-effect
evaporator (MEE), may be either an NDCE or DCE. Direct
contact evaporators use flue gases from the recovery furnace
to concentrate the black liquor. In the 1970's, as energy
costs increased and Federal and State regulations were
passed that limited TRS emissions from kraft pulp mills, the
use of NDCE's (or concentrators) became more prevalent. By
using an NDCE, the heat that was formerly used to
concentrate black liquor in the DCE can be used to produce
steam by extending the economizer section of the furnace,
and the TRS emissions (associated with the DCE) will be
decreased. For newer recovery furnaces, all of which use
NDCE's, the NDCE is often considered an integral part of the
MEE. Approximately 61 percent of kraft recovery furnaces
are NDCE recovery furnaces, and 39 percent are DCE recovery
furnace systems. For the purposes of today's proposed rule,
an "NDCE recovery furnace" is defined as a recovery furnace
that is equipped with an NDCE that concentrates black liquor
by indirect contact with steam. A UDCE recovery furnace
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49
system" is defined to include a DCE recovery furnace and any
BLO system, if present, at the pulp mill; a "DCE recovery
furnace" is defined as a recovery furnace that is equipped
with a DCE that concentrates strong black liquor by direct
contact between the hot recovery furnace exhaust gases and
the strong black liquor.
All kraft recovery furnaces have a PM control device,
typically an ESP. The PM collected in the ESP, which is
predominantly Na2SO4, is returned to the concentrated black
liquor that is fired in the recovery furnace. The mechanism
for returning .the PM to the black liquor may be a dry system
or may use either black liquor or process water.
In DCE recovery furnace systems, black liquor is
oxidized prior to evaporation in the DCE. Black liquor
oxidation reduces emissions of TRS compounds, which are
stripped from black.liquor in the DCE when the black liquor
contacts hot flue gases from the recovery furnace. Black
liquor can be oxidized using either air or pure (molecular)
oxygen. Air-sparging units operate by bubbling air through
the black liquor using multiple diffuser nozzles. Air-
sparging units have from one to three tanks (or stages) that
operate in series and a corresponding number of emission
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50
points. At two mills, vent gases from air-sparging BLO
units are routed to a power boiler to reduce TRS emissions
via incineration. Molecular oxygen BLO systems resemble
pipeline reactors and require relatively short residence
times (i.e., 30 seconds to 5 minutes compared to 1•or
more hours for air-sparging units). Because all of the
oxygen is consumed in the reaction, no system vent is
required with molecular oxygen BLO in-line reactors, and
therefore, no emission point is associated with these
systems. There are an estimated 46 BLO systems operating at
kraft pulp mills. Mills with multiple DCE recovery furnaces
have one BLO system. At present, only four mills (with
seven DCE recovery furnaces) use a molecular oxygen BLO
system.
The emission potential for DCE recovery furnace systems
is higher than that for NDCE recovery furnaces because of
the increased opportunity to strip HAP compounds from the
black liquor in the process equipment. In the DCE recovery
furnace system, gaseous organic HAP compounds can be
stripped from the black liquor in the air-sparging BLO
system and in the DCE. Similarly, the emission potential
for NDCE recovery furnaces with ESP's that use black liquor
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51
or HAP-contaminated process water in the ESP bottom or PM
return system is higher than that for NDCE recovery furnaces
that have dry ESP systems (i.e., dry-bottom ESP's and dry PM
return systems). As with the air-sparging BLO systems and
DCE's, stripping of gaseous organic HAP compounds can occur
if black liquor or HAP-contaminated process water is used in
the bottom of the ESP or in the PM return system.
In addition to the criteria pollutants (i.e., PM, NOX,
SO2/ CO, and VOC [ozone precursor]) and TRS, the compounds
emitted in the largest quantities from NDCE recovery
furnaces and DCE recovery furnace systems are methanol and
HC1. For a given process emission rate, the total gaseous
organic HAP emissions from DCE recovery furnace systems are,
on average, approximately 14 times higher than NDCE recovery
furnaces with dry ESP systems. Also, for a given process
emission rate, the total gaseous organic HAP emissions from
NDCE recovery furnaces with wet ESP systems (i.e., ESP's
that use black liquor or HAP-'contaminated process water in
the ESP bottom or PM return system) are, on average,
approximately 3.5 times- higher than NDCE recovery furnaces
with dry ESP systems. Of the total gaseous organic HAP's
emitted, methanol emissions account for approximately
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52
67 percent of emissions from DCE recovery furnace systems
and 13 percent of emissions from NDCE recovery furnaces with
dry ESP systems.
For a given process emission rate, HCl emissions are
approximately equivalent for both NDCE recovery furnaces and
DCE recovery furnace systems. Hydrogen chloride emissions
account for approximately 19 percent of the total gaseous
HAP emissions from DCE recovery furnace systems and
76 percent of the total gaseous HAP emissions from NDCE
recovery furnaces with dry ESP systems.
Particulate matter HAP's account for approximately
0.2 percent of the PM emissions and 0.3 percent of the total
HAP emissions from recovery furnaces. Although the PM inlet
loadings to the PM control devices for NDCE recovery
furnaces are higher than for DCE recovery furnaces due to
removal of 20 to 40 percent of the PM in the DCE unit,
equivalent outlet PM emissions can be achieved with the use
of add-on controls.
b. Smelt Dissolving Tanks. There are an estimated
227 SDT's at U.S. kraft pulp mills. This estimate is higher
than the estimated number of recovery furnaces because some
furnaces have two SDT's. The SDT is a large, covered vessel
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53 .
located below the recovery furnace and is the discharge
point for molten smelt, which is the main product from the
combustion of black liquor. Smelt, which is predominantly
sodium carbonate (Na2C03) and Na2S, filters through the char
bed at the bottom of the recovery furnace and is
continuously discharged through water-cooled spouts into the
SDT. As the smelt exits the water-cooled spouts, the smelt
stream is shattered with medium-pressure steam so that it
r
can be safely dissolved in the SDT. In the SDT, smelt is
dissolved in weak wash water from the recausticizing area to
form unclarified green liquor, an aqueous solution of Na2CO3
and Na2S.
Large volumes of steam are generated when the smelt is
quenched in the SDT. Residual water vapor and PM generated
during quenching are drawn off the tank through a venturi
scrubber or other PM control device using an induced-draft
fan. Particulate matter HAP's account for approximately
0.06 percent of the PM emissions from SDT's. The water used
in the scrubber, which is typically weak wash, drains
directly into the SDT. Gaseous organic HAP compounds
s
(primarily methanol) also are emitted from SDT's as a result
of the use of weak wash in the SDT and PM control device.'
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54
Because of the elevated operating temperature of the SDT,
gaseous organic HAP compounds present in the weak wash can
volatilize and subsequently be released to the atmosphere.
c. Lime Kilns. An estimated 190 lime kilns operate at
U.S. kraft pulp mills. The lime kiln is part of the
recausticizing process in which green liquor from the SDT is
converted to white liquor. Specifically, Na2CO3 in the
green liquor is converted to NaOH, a main constituent of
white liquor, by adding reburned lime (CaO) from the lime
kiln. The resulting white liquor solution contains NaOH,
Na2S, and calcium carbonate (Ca2CO3) precipitate (referred to
as "lime mud"). Lime mud is removed from this solution in a
white liquor clarifier. The lime mud is then washed,
dewatered, and calcined in a lime kiln to produce reburned
lime, which is recycled back to the green liquor.
Most kilns in use at kraft pulp mills are large rotary
kilns (98 percent); a few fluidized-bed calciners are also
used. Natural gas or fuel oil typically provides the energy
for the calcining process. The majority of lime kilns at
kraft pulp mills also burn noncondensible gas streams
(NCG's) from various process vents, such as digester and
evaporator vents.
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55
Lime kiln exhaust gases consist of combustion products,
carbon dioxide released during calcination, water vapor
evaporated from the mud, and entrained lime dust.
Particulate in the exhaust gases is mainly CaO, Ca2CO3/ and
sodium salts. Approximately. 1.4 percent of the PM emissions
from lime kilns is PM HAP's. Exhaust gases are routed
through a PM control device prior to being discharged to the
atmosphere. Venturi scrubbers and ESP's are the two most
common types of PM control devices used to control PM
emissions from lime kilns.
As with SDT's, gaseous organic HAP compounds (primarily
methanol) also are emitted from lime kilns due primarily to
the use of weak wash as' the scrubbing liquor in the PM
control device and lime .mud washer. Because of the elevated
gas stream temperature, gaseous organic HAP compounds
present in the weak wash can volatilize and subsequently be
released to the atmosphere.
2. Emission Points--Soda Pulp Mills
Emission points at soda pulp mills that were examined
'by the Agency for control under today's proposed standards
are recovery furnaces, SDT''s, and lime kilns. The processes
and equipment used in the chemical recovery areas of soda
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and kraft pulp mills are similar, except that the soda
process, because it is a nonsulfur process, does not require
black liquor oxidation. With the exception of sulfur-
containing compounds, the types and quantities of compounds
emitted from soda pulp mills are comparable to the types and
quantities of compounds emitted from kraft pulp mills.
There are only two soda pulp mills in the United States, and
no new soda mills are expected to be constructed. There are
a total of two recovery furnaces (one NDCE and one DCE), two
SDT's, and two lime kilns at the soda mills.
3 . Emission Points — Suitite Pulp Mills
The emission point at sulfite pulp mills that was
examined by the Agency for control under the proposed
standard is the chemical recovery combustion unit. The
chemical recovery combustion unit is an integral part of the
chemical recovery process, which recovers cooking liquor
chemicals from spent cooking liquor (also called red
liquor). The types of chemical recovery combustion units
used at sulfite mills are recovery furnaces, fluidized-bed
reactors, and combustors. There are 18 recovery furnaces,
2 fluidized-bed reactors, and 1 combustor operating at
sulfite pulp mills. For the purposes of today's proposed
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rule, these various combustion units are collectively
referred to as "sulfite- combustion units."
The process and equipment used to recover sulfite
cooking liquor chemicals depend on the chemical base of the
cooking liquor. Sulfite cooking liquors use one of four
chemical bases--magnesium (Mg), ammonia (NH3), calcium (Ca),
or sodium (Na). Cooking liquor chemicals can be recovered
for the Mg-, NH3-, and Na-based sulfite processes. Recovery
of cooking liquor chemicals is not practical for the Ca-
based sulfite process, and, therefore, no sulfite combustion
units are used at the existing Ca-based sulfite mills.
Additionally, there are currently no operating Na-based
sulfite mills. There are currently six Mg-based sulfite
mills and six NH3-based sulfite mills. Information on the
sulfite combustion units at Mg- and NH3-based sulfite pulp
mills follows.
At the six Mg-based sulfite mills, red liquor is fired
in a recovery furnace or fluidized-bed reactor. There are
nine recovery furnaces and two fluidized-bed reactors.
Multiple-effect evaporators, which may be followed by a DCE
or NDCE, are used to increase the solids content of the red
liquor prior to firing in the combustion unit. Magnesium-
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based sulfite combustion units differ from kraft recovery-
furnaces in that there are no smelt beds. Combustion of the
spent liquor produces both heat for steam generation and .
exhaust gases that contain magnesium oxide (MgO) particulate
and SO2 gas. When a recovery furnace is used, the major
portion of the MgO is recovered as a fine white powder from
the exhaust gases using multiple cyclones. When a
fluidized-bed reactor is used, MgO from the exhaust gases is
collected in a cyclone and from the bed of the reactor as
pulverized bed material. The MgO from the recovery furnace
or fluidized-bed reactor is then slaked with water to form
magnesium hydroxide (Mg(OH)2), which is used as circulating
liquid in a series of absorption towers and/or venturi
scrubbers designed to recover SO2 from combustion gases. In
the absorption towers/venturi scrubbers, S02 is recovered by
reaction with Mg(OH)2 to form a magnesium bisulfite
solution. The magnesium bisulfite solution is then
fortified with makeup SO2 and subsequently used as cooking
liquor. Some mills have installed air pollution control
devices, such as a fiber-bed demister system or an educted
venturi scrubber, downstream of the SO2 absorption
equipment, to further reduce PM and/or SO2 emissions.
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At the six NH3-based sulfite pulp mills, red liquor is
fired in a recovery furnace or combustor. There are nine
recovery furnaces and one combustor. The solids content of
the red liquor is increased using MEE's, which may be
followed by a DCE or NDCE. Combustion of the spent liquor
produces both heat for steam generation and combustion gases
that contain recoverable SO2. The ammonia base is consumed
during combustion, forming nitrogen and water. A small
amount of ash is produced and periodically -removed from the
furnace bottom. (There are no smelt beds.) Sulfur dioxide
is recovered from cooled flue gas in an acid-gas absorption
tower to form an ammonium bisulfite solution. Fresh aqueous
NH3 is used as the circulating liquor in the absorption
system. The ammonium bisulfite solution is fortified with
makeup SO2 and used as cooking liquor. Exit gases from the
absorption system are typically routed to a fiber-bed
demister system for PM removal and mist elimination prior to
being discharged to the atmosphere. Some mills have
installed a scrubber or mesh-pad mist eliminator upstream of
the fiber-bed demister system for additional PM and SO2
emission control and to improve the efficiency and operation
of the fiber-bed demister system.
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4. Emission Points--Stand-alone Semichemical Pulp
Mills
The emission point at stand-alone semichemical pulp
mills that was examined for control under today's proposed
standards is the chemical recovery combustion unit. The
combustion unit is used in the chemical recovery process to
recover the inorganic cooking chemicals, produce 'steam, and
remove the organic compounds in the black liquor by
combustion. Cooking liquor chemicals are recovered as
either smelt or ash, which is dissolved in water and mixed
with make-up cooking chemicals to form white liquor.
There are 14 chemical recovery combustion units
currently operating at stand-alone semichemical pulp mills.
Five different types of chemical recovery combustion units
are in operation: fluidized-bed reactors, recovery
furnaces, smelters, rotary liquor kilns, and pyrolysis
reactors. For the purposes of today's standards, these
various combustion units are collectively referred to as
"semichemical combustion units."
a. Fluidized-Bed Reactors. Seven fluidized-bed
reactors are currently in use at seven stand-alone
semichemical pulp mills. Fluidized-bed reactors are used
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extensively because the recovered chemicals are in the form
of solid pellets, which can be stored in silos until the
chemicals are needed, to make fresh cooking liquor. This
practice requires less storage space than when recovered
chemicals are routed directly to a dissolving tank and
stored in solution.
In the fluidized-bed reactor, concentrated black liquor
is fired from a single spray gun located at the top of the
reactor. As the liquor falls towards the bed, evaporation
and some combustion occurs, causing the liquor to pelletize.
Fluidizing gas rises through the bed of solid pellets,
setting the bed in fluid motion. The soda ash (Na2CO3)
pellets are recovered from the reactor and stored in silos.
b. Recovery-Furnaces. Two NDCE recovery furnaces are
currently in use at two stand-alone semichemical pulp mills.
Semichemical recovery furnaces, like kraft recovery
furnaces, are used to recover cooking liquor chemicals by
burning concentrated black liquor and to produce process
steam with the heat of combustion. Semichemical and kraft
recovery furnaces are similar in design.
c. Smelters. Two smelters are currently in use at a
nonsulfur-based, stand-alone semichemical pulp mill.
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Smelters operate in a manner similar to recovery furnaces,
except that smelters do not produce excess steam for mill
processes and are actually net users of heat. The units
currently in use are actually converted small kraft recovery
furnaces.
d. Rotary Liquor Kilns. Two rotary liquor kilns are
currently in use at two nonsulfur-based, stand-alone
semichemical pulp mills. Unlike lime kilns used in the
kraft chemical recovery process, rotary liquor kilns are
used for the combustion of black liquor at semichemical pulp
mills. In the kiln, fuel oil is burned in the lower, end.
An induced-draft fan at the upper end draws combustion air
into the lower end and draws combustion gases through the .
kiln. Approximately halfway between the lower and upper
ends, black liquor is fired into the kiln. Sodium carbonate
ash created from contact between black'liquor and combustion
gases falls to the lower end of the kiln, then is routed to
an ash dissolving tank. The combustion gases are routed to
a waste heat boiler to produce steam.
e. Pyrolysis Reactor. One pyrolysis reactor is
currently in use at a stand-alone semichemical pulp mill.
"Pyrolysis" means chemical change caused by heat, not by
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combustion. In the pyrolysis reactor, fuel oil or propane
is burned to provide the heat for pyrolysis. Black liquor
is injected under high pressure in a finely atomized spray
through several nozzles arranged around the wall of the
pyrolysis chamber. The hot combustion gases travel downward
at high velocity and contact the liquor sprays at high
turbulence and rapid mixing. Pyrolysis reactions occur,
converting the sodium in the liquor into a solid ash powder
composed mainly of soda ash (Na2CO3) , and the other
constituents into a gaseous mixture of hydrogen sulfide
(H2S) mixed with CO, carbon dioxide (C02) , hydrogen (H2) ,
methane (CH4) , nitrogen (N2) , and water vapor.
f. HAP Emissions from Semichemical Combustion Sources.
Test data indicate that chemical recovery combustion units
at stand-alone semichemical pulp mills are significant
sources of gaseous organic HAP emissions. The major HAP
compounds emitted from chemical recovery combustion units
are methanol, benzene, methyl ethyl ketone', formaldehyde,
and toluene. The fluidized-bed reactors emit the highest
quantities of. HAP1s, while emissions from other semichemical
combustion unit types (e.g., recovery furnaces and rotary
liquor kilns) are much lower. For example, based on
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available HAP emissions data, the fluidized-bed reactors
have total HAP emissions approximately 20 to 75 times higher
per ton of black liquor solids fired than the other
semichemical combustion unit types. Some of the other
setnichemical combustion unit types (e.g., recovery furnaces
and rotary liquor kilns) are inherently lower-emitting
because they achieve more complete combustion of organic
compounds. (No HAP emission data were available for'the
pyrolysis unit; however, that unit is scheduled to be
decommissioned by 1998 due to operational difficulties, and
no more pyrolysis units are expected to be installed at
stand-alone semichemical pulp mills.) Unlike kraft recovery
furnaces, most of the HAP's emitted from fluidized-bed
reactors at stand-alone semichemical pulp mills are formed
in the reactor due to incomplete combustion, not from
contact of the exhaust stream with black liquor or HAP-
contaminated water in the DCE or wet ESP systems. Carbon
monoxide emissions, an indicator of combustion efficiency,
have been measured from fluidized-bed reactors at levels as
high as 50,000 parts per million by volume (ppmv) ; by
contrast, kraft recovery furnaces typically emit less than
1,000 ppmv of CO. No add-on control devices are currently
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being used to control total gaseous organic HAP emissions
from combustion sources at stand-alone semichemical pulp
mills; however, at least one RTO will be installed to
control emissions from a fluidized-bed reactor at a
semichemical mill by the end of 1997..
C. Selection of Definition of Affected Source
Most industrial plants consist of numerous pieces or
groups of equipment that- emit HAP and that may be viewed as
emission "sources." The Agency, therefore, uses the term
"affected source" to designate the equipment within a
particular kind of plant that is chosen as the "source"
covered by a given standard. For today's rulemaking, EPA is
proposing to define the affected source as each individual
process unit within the chemical recovery area at kraft,
soda, sulfite, and stand-alone semichemical pulp mills. For
kraft and soda pulp mills, each recovery furnace and its
associated SDT(vs) are considered together as an affected
source. The Agency decided to consider.these emission
points as one source because recovery furnaces and SDT's are
generally sold as one unit, although the emissions, from the
recovery furnace and the SDT are treated separately in
nearly all cases. In today's proposed rulemaking, five
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process units are examined: (1) kraft and soda NDCE
recovery furnaces (and associated SDT's), (2) kraft and soda
DCE recovery furnace systems (and associated SDT's),
(3) kraft and soda lime kilns, (4) sulfite combustion units,
and (5) semichemical combustion units.
D. Selection of Pollutants
For purposes of this rule, the HAP's emitted from
combustion sources at pulp mills have been divided into
three categories: (1) PM HAP's, (2) total gaseous organic
HAP's, and (3) HCl. The EPA proposes to regulate emissions
of PM HAP's and gaseous organic HAP's.
1. PM HAP's
Available emission data indicate that PM HAP's are
emitted from kraft and soda recovery furnaces, SDT's, and
lime kilns and sulfite combustion units. Particulate matter
HAP's represent approximately 0.2 percent of the PM emitted
from these combustion sources. Particulate matter was
selected as a surrogate for HAP metals emitted in the form
of particulate. Available data on PM control device
performance indicate that control systems that control PM
also control the HAP portion of the PM. (See Technical
Support Document: Chemical Recovery Combustion Sources at
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Kraft and Soda Pulp Mills, Chapter 3; docket No. II-A-31.)
However, as a means of maximizing compliance flexibility,
the proposed rule also includes a PM HAP emission limit for
existing affected sources at kraft and soda mills that
choose to measure PM HAP's directly, as opposed to measuring
PM. .
2. Total Gaseous Organic HAP's
Available emission data indicate that the following
gaseous organic HAP's are 'emitted from kraft and soda NDCE
recovery furnaces and DCE recovery furnace systems and
semichemical combustion units: acetaldehyde, benzene,
formaldehyde, methyl ethyl ketone, methyl isobutyl ketone,
methanol, phenol, styrene, toluene, and xylenes. Methanol
is the predominant gaseous organic HAP-emitted from kraft
and soda NDCE recovery furnaces and DCE recovery furnace
systems.
Methanol was selected as a surrogate for gaseous
organic HAP compounds for demonstrating compliance with the
total gaseous organic HAP limits for new kraft and soda NDCE
recovery furnaces and DCE recovery furnace systems because
methanol is the predominant HAP emitted from these sources,
and controls in place for methanol also would result in the
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control of other gaseous organic HAP compounds. (See
Technical Support Document: Chemical Recovery Combustion
Sources at Kraft and Soda Pulp Mills, Chapter 2; docket
No. II-A-31.) For example, the major emission mechanism for
the release of gaseous organic HAP compounds is the
stripping of the compounds from the black liquor in the BLO
unit, the DCE, and some ESP systems. Reducing contact
between the gas streams and the black liquor in these units
reduces not only methanol emissions but also emissions of
other gaseous organic HAP's. In addition, performance tests
are more expensive when a range of organic compounds must be
measured. The measurement of methanol as a surrogate for
gaseous organic HAP's reduces compliance costs. Therefore,
the Agency selected methanol as a surrogate for total
gaseous organic HAP emissions for new kraft and soda NDCE
recovery furnaces and DCE recovery furnace systems.
For new and existing semichemical combustion units, THC
emissions were selected as a surrogate for total gaseous
organic HAP emissions. Emissions from semichemical
combustion units are primarily the result of incomplete
combustion, and THC emissions were found to, correlate with
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HAP emissions. (See Correlation of THC Emissions with HAP
Emissions Memo; docket No. II-B-71.)
3. HC1
The Agency proposes not to regulate HC1 emissions from
recovery furnaces. Under the authority of
section 112(d)(4), the Agency has determined that no further
control is necessary because HCl is a "health threshold
pollutant," and HCl levels emitted from recovery furnaces
are below the threshold value within an ample margin of
safety. The following discussion provides the basis for the
Agency's decision not tp regulate HCl emissions from
recovery furnaces. Specifically, this section discusses (1)
the statutory authority for considering the health threshold
when establishing standards, (-2) the determination of HCl as
a threshold pollutant, (3) the exposure assessment modeling
of HCl emissions from recovery furnaces, (4) an ecological
assessment of HCl, and (5) the Agency's conclusions.
a. Statutory Authority. The Act includes certain
exceptions to the general statutory requirement to establish
emission standards based on the performance of MACT. Of
relevance here, section 112(d)(4) provides EPA with
authority, at its discretion, to develop risk-based
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standards for HAP's "for which a health threshold has been
established", provided that the standard achieves an "ample
margin of safety." (The full text.of the section 112(d)(4):
"[w]ith respect to pollutants for which a health threshold
has been established, the Administrator may consider such
threshold level, within an ample margin of safety, when
establishing emission standards under this subsection.")
The EPA presumptively applies section 112(d)(4) only to
HAP's that are not carcinogens because Congress clearly
intended that carcinogens be considered nonthreshold
pollutants. (Staff of the Senate Committee on Environment
and Public Works, A Legislative History of the Clean Air Act
Amendments of 1990, Vol. 1 at 876, statement of Senator
Durenberger during Senate Debate of October 27, 1990: "With
respect to the pollutants for which, a safe threshold can be
set, the authority to set a standard less stringent than
maximum achievable control technology is contained in
subsection (d)(4). With respect to carcinogens and other
non-threshold pollutants, no such authority exists in
subsection (d) or in any other provision of the Act.") The
legislative history further indicates that if EPA invokes
this provision, it must assure that any emission standard
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results in ambient concentrations less than the health
threshold, with an ample margin of safety, and that the
standards must also be sufficient to protect against adverse
environmental effects (S. Rep. No. 228, 101st Cong, at 171).
Costs are not to' be considered in establishing a standard
pursuant to section 112(d)(4) (Ibid.).
Therefore, EPA believes it has the discretion under
section 112(d)(4) to develop risk-based standards for some
categories emitting threshold pollutants,,which may be less
i
stringent than the corresponding "floor"-based MACT standard
would be. If EPA decided to develop standards under this
provision, it would seek to assure that emissions from every
source in the category or subcategory are less than the
threshold, level to an individual exposed at the upper end of
the exposure distribution. The upper end of the exposure
distribution is calculated using the "high end exposure
estimate," defined as "a plausible estimate of individual
exposure for those persons at the upper end of the exposure
distribution, conceptually above the 90th percentile, but
not higher than the individual in the population who has the
highest exposure" (EPA Exposure Assessment Guidelines, 57 FR
22888, May 29, 1992). The EPA believes that assuring
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protection to persons at the upper end of the exposure
distribution is consistent with the . "ample margin of safety"
requirement in section 112(d)(4).
The EPA emphasizes that use of section 112(d)(4)
authority is wholly discretionary. As the legislative
history described above indicates, cases may arise in which
other considerations dictate that the Agency should not
invoke this authority to establish less stringent standards,
despite the existence of a health effects threshold that is
not jeopardized. For instance, EPA does not anticipate that
it would set less stringent standards where evidence
j.**^.,.,—^w~ - — = -- — r
environmental effects, although it may be shown that
emissions from a particular source category do not approach
or exceed a level requisite to protect public health with an
ample margin of safety. The EPA may also elect not to set
less stringent standards where the estimated health
threshold for a contaminant is subject to large uncertainty.
Thus, in considering appropriate uses of its discretionary
authority under section 112(d)(4) / EPA intends to consider
other factors in addition to health thresholds, including
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uncertainty and potential "adverse environmental effects,"
as that phrase is defined in section 112(a)(7).
b. Health Effects Assessment. Several factors are
considered in the Agency's decision of whether a pollutant
should be categorized as a health threshold pollutant for
the purposes of section 112(d)(4). These factors include
evidence and classification of carcinogenic risk' and
evidence of noncarcinogenic effects. The following
discussion focuses on these factors.
Consideration is given to any evidence of human
carcinogenic risk associated with the pollutant. Based on
Congress's intent, for the purposes of section 112(d)(4),
the Administrator presumptively concludes that HAP's
classified as either Group A (known carcinogen), Group B
(probable carcinogen), or Group C (possible carcinogen) (as
defined under the EPA's 1986 Carcinogen Risk Assessment
Guidelines (51 FR 33992; September 24, 1986)) should not be
categorized as threshold pollutants (as per
section 112(f)(2)(A) of the Act, which requires EPA to
consider residual risk standards for pollutants classified
as "known, probable, or possible human carcinogens"). The
EPA recognizes that advances in risk assessment science and
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policy, as incorporated in future EPA risk assessment
guidelines, may affect the way EPA differentiates between
threshold and non-threshold HAP's. The EPA's draft
Guidelines for Carcinogen Risk Assessment (public review
draft, April, 1996) suggest that carcinogens be assigned
non-linear dose-response relationships where data warrant.
It is possible that dose-response curves for some substances
may reach zero risk at a dose greater than zero, creating a
threshold for carcinogenic effects. The EPA will consider
both the state of the science and legislative intent in
future rulemaking under section 112(d)(4). Under EPA's
current guidelines, the Agency considers the data on
carcinogenicity in humans and/or animals for pollutants with
A, B, or C classifications adequate support for
consideration of a HAP as a nonthreshold pollutant.
By definition, the Agency does not have enough evidence
available to conclude whether HAP's with the weight of
evidence classification of Group D (as defined under the
EPA's 1986 Carcinogen Risk Assessment Guidelines [51 FR
33992; September 24> 1986]) pose a human cancer risk. Thus,
the Agency will determine, on a case-by-case basis, whether
the available evidence is sufficient to conclude whether a
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"safety threshold for exposure" exists for each HAP that is
classified as a Group D pollutant. For the purposes of this
action, the Agency believes it is reasonable to classify HC1
as a Group D pollutant (see Health Assessment Document for
Chlorine and Hydrogen Chloride, Review Draft;
EPA-600/8-87/041A, August 1994). .This classification is
based on only one animal study, and no human data are
available for review. In the animal study, no carcinogenic
response was observed in rats exposed via inhalation. Based
on the limited negative carcinogenicity data, and on EPA's
knowledge of how HCl reacts in the body and its likely
mechanism of action (discussed further below), the Agency
presumptively considers HCl to be a threshold pollutant.
Under current EPA science policy, HAP' s classified as
Group E pollutants (evidence of noncarcinogenicity for
humans) are presumptively considered by the Agency, for the
purposes of section 112(d)(4), to have a "safety threshold
of exposure." Therefore, Group E pollutants are considered
threshold pollutants, unless there is adequate evidence to
the contrary. The EPA has developed new risk assessment
guidelines for reproductive effects (see
http://www.epa.gov/ORD/WebPubs/repro), and is in the process
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of developing others (e.g., developmental effects and
neurotoxicity) that may influence determinations of
thresholds for specific pollutants.
For pollutants such as HCl that are considered to have
a "threshold of safety" below which adverse effects are not
expected, the information on noncarcinogenic effects must
be evaluated to determine the potential hazards associated
with exposure to the pollutant. One approach for
determining potential hazards of a pollutant is to use its
Inhalation Reference Concentration (RfC). The RfC is
defined -as an estimate (with uncertainty spanning perhaps an
order of magnitude) of a daily inhalation exposure that,
over a lifetime, would not likely result'in the occurrence
of noncancer health effects in humans. A health benchmark
such as the RfC can be established by applying uncertainty
factors to the critical toxic effect derived from the lowest
or no-adverse-effect level of a pollutant (see
EPA-600/8-90-066F, October 1994, Methods for Derivation of
Inhalation Reference Concentrations and Applications of
Inhalation Dosimetry). The confidence in the RfC (which is
given a qualitative ranking of either high, medium, or .low)
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is based on the number of studies available and the quality
of the data base, among other things.
The RfC for HC1 is based on a single animal study,
which used only one dose and had limited toxicological
measurements. In that study, laboratory rats exposed to
15,000 /ig/m3 HC1 for 6 hours per day, 5 days per week for
life, developed an increased incidence of hyperplasia of the
larynx and trachea, compared to controls (Health Assessment
Document for Chlorine and Hydrogen Chloride, Review Draft;
EPA-600/8-87/041A, August 1994). Effects on laboratory
animals exposed to even higher concentrations of HCl for
90 days included damage to the organs of the respiratory
system, but not to more distant organs. Chronic exposure
studies involving lower concentrations (less than
15,000 //g/m3) have not been done, nor have comprehensive
epidemiological studies of humans (Health Assessment
Document for Chlorine and Hydrogen Chloride, Review Draft;
EPA-600/8-87/041A, August 1994).
The RfC for HCl is 20 /xg/m3 (EPA, 1995, Integrated Risk
Information.System (IRIS), Reference Concentration (RfC) for
Inhalation Exposure for Hydrogen Chloride. National Center
for Environmental Assessment, Cincinnati, OH. On-Line).
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This concentration is a low confidence RfC with an
uncertainty factor of 300 applied to the lowest adverse
effect level noted in animals (Ibid).
Generally, information on developmental and
reproductive effects would provide additional confidence in
the adequacy of the health benchmark for characterizing
health risk. No information is available on the
developmental or reproductive effects associated with HC1
exposure in humans or animals. However, no additional
uncertainty is applied for the lack of these studies because
HCl that deposits in the lung is not expected to have any
effects at sites distant from the lung. Hydrogen chloride,
in solution, quickly dissociates to H+ (which, in small
doses, is buffered in the tissue or blood) and Cl~ (which is
ubiquitous in the body). Therefore, HCl is expected to have
only local effects at the-site of initial deposition.
Furthermore, HCl is not thought to be directly genotoxic
(Health Assessment Document for Chlorine and Hydrogen
Chloride, Review Draft; EPA-600/8-87/041A, August 1994) .
Based on the information presented above, the
Administrator has determined that HCl is a health threshold
pollutant for the purpose of section 112(d)(4) of the Act.
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The Administrator also concludes that, in this case, the RfC
is an appropriate threshold value for assessing risk to
humans associated with exposure to this pollutant through
inhalation.
c. Exposure Assessment. Based on emission tests of 14
kraft recovery furnaces, uncontrolled HC1 emissions from DCE
and NDCE recovery furnaces range from 0 to 923 Mg/yr (0 to
1,016 tons/yr); however, the concentrations of HCl in
recovery furnace exhaust gases (0.3 to 95.6 ppmj are
relatively low due to the high volume of the exhaust gases.
Chlorides enter the liquor cycle primarily through the wood
used for pulping and the caustic used as makeup chemical
during white liquor preparation, although mill process water
can also be a significant contributor. A small portion of
the chlorides in the black liquor fed to the recovery
furnace can be emitted from the furnace as HCl gas. The
remaining chlorides in the black liquor exit the recovery
furnace as inorganic alkali salts, either as particulate in
the exhaust gases or as a constituent of the smelt.
For sulfite combustion units, HCl emissions are
negligible because acid-gas absorption systems are an
integral part of the sulfite chemical recovery process.
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Hydrochloric acid emissions data are available for only one
sulfite combustion unit; HC1 emissions from this unit were
approximately 1 pprriv following the acid-gas absorption
system. No data are available on HCl emissions prior to the
acid-gas absorption systems. No HCl emission data are
available for semichemical combustion units. However,
neither process nor technical considerations indicate that
HCl emissions would be significant.
Inputs for the exposure assessment model were developed
for kraft and soda recovery furnaces, which have the higher
HCl emissions. The inputs were developed using available
test data and mill-specific process data. Estimated HCl
emission rates were based on the highest available HCl
emission factors (in units of kilograms [kg] of HCl per kg
of black liquor solids fired) for both NDCE and DCE recovery
furnaces. Because the HCl emission rates were based on
mill-specific process data (e.g., black liquor solids firing
rate), each recovery furnace type at each mill had a unique
set of emissions estimates. Stack parameters (i.e., height,
diameter, temperature and velocity) were based on
information obtained from the AIRS data base; average values
from AIRS were assigned to those sources for which AIRS data
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were not available. For mills with multiple recovery
furnaces (e.g., two NDCE recovery furnaces), HC1 emissions
from the furnaces were summed, and the stack parameters for
those recovery furnaces were averaged.
This exposure assessment was conducted following the
principles described in the Agency's Exposure Assessment
Guidelines (57 FR 22888, May 29, 1992). There is no
expectation that the population will be exposed to higher
long-term levels of HCl than those predicted by the model.
In this case, a screening analysis was used to determine if
emissions of HCl could result in exposures above Agency-
established health threshold concentrations. The assessment
was conducted for 106 mills. The applied approach
incorporates into the analysis ranges of values for those
variables meeting the following criteria: where
mathematical distributions are available; where the
variables are independent; and, most importantly, where the
variables are believed to significantly influence the
results of the analysis. This probabilistic procedure uses
Monte Carlo simulation to produce distributions with
associated probability estimations (e.g., there is a
95 percent probability that the estimated exposure to the
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most exposed population group (census block) is less than
the RfC for HCl).
The distributions used in the Monte Carlo analysis were
taken primarily from EPA sources (such as the Exposure
Factors Handbook; EPA/600/8-89/043, July 1989) and the
literature. Best judgments were used in selecting the
distributions and, in some cases, in using only portions of
the distributions that are provided in the Handbook. Use of
other distributions may result in different final outcomes
for the Monte Carlo analysis. -
The results of this analysis show that, at the
95 percent confidence interval, the maximum concentration
predicted to which people are estimated to be exposed is
0.3 ywg/m3, 60 times less than the inhalation reference
concentration.
In addition, terrain (e.g., hills and valleys) is known
to affect concentration estimates predicted near facilities
with elevated pollutant releases (e.g., stacks). The effect
of terrain on estimated HCl concentrations was investigated
by including terrain in the modeling of the ten recovery
furnaces that produced the highest estimated HCl
concentrations at census blocks in the exposure assessment
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described above. The terrain analysis and a Monte Carlo
assessment similar to that described above resulted,, at the
95 percent confidence interval, in a maximum concentration
to which people are expected to be exposed of 2 /^g/m3, which
is 10 times less than the inhalation reference
concentration.
d. Ecological Assessment. The standards for emissions
must also protect against significant and widespread adverse
environmental effects to wildlife, aquatic life, and other '
natural resources. Approaches to ecological risk
assessments are being developed and applied by EPA for
several areas of concern regarding the effects of
pollutants. For HC1 emitted by these source categories, a
formal ecological risk assessment as such has not been made.
However, publications in the literature have been reviewed
to determine if there would be reasonable expectation for
serious or widespread adverse effects to natural resources.
Aspects of pollutant exposure and effects that should .
be considered are: toxicity effects from acute and chronic
exposures to expected concentrations around the source (as
measured or modeled), persistence in the environment, local
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and long-range transport, and tendency for bio-magnification
with toxic effects manifest at higher trophic levels.
No research has been identified for effects on
terrestrial animal species beyond that cited in the
development of the RfC. The evidence available to date,
discussed in section IV.D.S.b of this preamble, indicates
that HC1 is a threshold pollutant for the purposes of
section 112(d)(4) of the Act. Modeling calculations
indicate that there is little likelihood of chronic or
widespread exposure to HC1 at concentrations above the
threshold around pulp and paper mills. Based on these
i
considerations, EPA believes that the RfC can reasonably be
expected to protect against widespread adverse effects in
other animal species as well.
Plants also respond to airborne HC1 levels. Chronic
exposure to about 600 ^g/m3, can be expected to result in
discernible effects, depending on the plant species. Plants
respond differently to HC1 as an anhydrous gas than to HCl
aerosols. Relative humidity is important in plant response;
there appears to be a threshold of relative humidity above
which plants will incur twice as much damage at a given dose
(Medical and-Biological Effects of Environmental Pollutants:
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Chlorine and Hydrogen Chloride, National Academy of
Sciences, 1976). Effects include leaf injury and decrease
in chlorophyll levels in various species given acute,
20-minute exposures of 6,500 to 27,000 ftg/m3 (Health
Assessment Document for Chlorine and Hydrogen Chloride,
Review Draft; EPA-600/8-87/041A, August 1994). A field
study reports different sensitivity to damage of foliage in
50 species growing in the vicinity of an anhydrous aluminum
chloride manufacturer. American elm, bur oak, eastern white
pine, basswood, red ash and several bean species were
observed to be most sensitive. Concentrations of HC1 in the
air were not reported. Chloride ion. in whole leaves was 0.2
to 0.5 percent of dry weight; sensitive species showed
damage at the lower value, but tolerant species displayed no
injury at the higher.value. Injury declined with distance
from the source with no effects observed beyond 300 meters
(Harper and Jones, 1982, "The relative Sensitivity of Fifty
Plant Species to Chronic Doses of Hydrogen Chloride,"
Phytopathology 72:.261-262). ;
Prevailing meteorology strongly determines the fate of
HC1 in the atmosphere (Health Assessment Document for
Chlorine and Hydrogen Chloride, Review Draft;
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EPA-600/8-87/041A, August 1994). However, HCl is not
considered a strongly persistent pollutant, or one where
long range transport is important in predicting its
ecological effects. In the atmosphere, HCl can be expected
to be absorbed into aqueous aerosols, due to its great
affinity for water, and removed from the troposphere by
rainfall. In addition, HCl will react with hydroxy ions to
yield water plus chloride ions. However, the concentration
of hydroxy ions in the troposphere is low, so HCl may have a
relatively long residence time in areas of low humidity. No
studies are reported of HCl levels in ponds or other small
water bodies or soils near major sources of HCl emissions.
Toxic effects of HCl to aquatic organisms would likely be
due to the hydronium ion, or acidity. Aquatic organisms in
their natural environments often exhibit a broad range of pH
tolerance. Effects of HCl deposition to small water bodies
and to soils will primarily depend on the extent of
neutralizing by carbonates or other buffering compounds
(Health Assessment Document for Chlorine and Hydrogen
Chloride, Review Draft; EPA-600/8-87/041A, August 1994).
Chloride ions are essentially ubiquitous in natural waters
and soils, so minor increases due to deposition of dissolved
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HC1 will have much less effect than the deposited hydronium
ions. Deleterious effects of HCl-on ponds and soils, where
such effects might be found near a major source emitting to
the atmosphere, likely will be local rather than widespread,
as observed in plant foliage.
Effects of HCl on tissues are generally restricted to
those immediately impacted and are essentially acidic
effects. The rapid solubility of HG1 in aqueous media
releases hydronium ions, which can be corrosive to tissue
when above a.-threshold concentration. The chloride ions may
be concentrated in some plant tissues, but may be
distributed throughout the organism, as most organisms have
chloride ions in their fluids. Leaves or other tissues
exposed to HCl may show some concentration above that of
their immediate environment; that is, some degree of
bioconcentration can occur. However, long-term storage in
specific organs and biomagnification of concentrations of
HCl in trophic levels of a food chain would not be expected.
Thus, the chemical nature of HCl results in deleterious
effects, that when present, are local rather than
widespread.
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e. Conclusions. The results of the exposure
assessment modelling showed exposure levels to HC1 emissions
from kraft and soda recovery furnaces below the health
threshold value. Furthermore, the threshold value, for
which the RfC was determined to be an appropriate value, was
not exceeded when taking into account an ample margin of
safety. Finally, no significant or widespread adverse
environmental effects from HCl are anticipated. Therefore,
the Agency, under authority of section 112(d)(4), has
determined that further control of HCl emissions from kraft
and soda recovery furnaces and sulfite and semichemical
combustion units is not necessary.
E. Determination of Subcategories and MACT Floors
The first step in establishing MACT floors is to
determine whether the source category warrants
subcategorization. In evaluating the chemical recovery
process for subcategorization, the Agency took into
consideration the type of equipment used in the process, the
emission potential of each emission point, and any
variations in the process due to pulp type. The Agency
determined that the chemical recovery areas at kraft and
soda pulp mills do not warrant subcategorization because the
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recovery areas are comparable in processes, equipment, and
HAP emissions. The Agency determined that separate
subcategories are warranted for sulfite and stand-alone
semichemical pulp mills because the recovery processes used
at sulfite and stand-alone semichemical pulp mills are
specifically different from each other and from those used
at kraft and soda pulp mills.
The proposed MACT floors for each category were
established on an emission point basis. For existing
sources at kraft and soda pulp mills, the MACT floor was
established by examining the emission level achievable by
the control technology used by the source at the
94th percentile (i.e., the median emission limitation
achieved by the top 12 percent of sources). Because there
are fewer than 30 sulfite combustion units nationwide, the
proposed MACT floor for existing sources at sulfite pulp
mills was established by examining the emission level
achieved by the control technology used by the best-
performing five existing sources at sulfite pulp mills. The
MACT floor approach used for existing sources at sulfite
pulp mills was also used for existing sources at stand-alone
semichemical pulp mills because there are fewer than
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30 semichemical combustion sources. The MACT floor
technologies for new sources at kraft, soda, sulfite, and
stand-alone semichemical pulp mills are based on the best-
performing similar source for each subcategory. The control
technologies and corresponding emission levels that
represent the proposed MACT floors were determined based on
technology and emission data that were available to the
Administrator.
1. MACT Floors--Kraft and Soda Pulp Mills
This section provides a brief description of the MACT
floor determinations for kraft and soda NDCE recovery
furnaces, DCE recovery furnace systems, lime kilns, and
SDT's.
a. NDCE Recovery Furnaces. An estimated 128 NDCE
recovery furnaces operate at 96 U.S. kraft and soda pulp
mills. Information regarding the furnace type, size, and
add-on control devices is available for approximately
88 percent of these recovery furnaces. Ninety-seven percent
of NDCE recovery furnaces are equipped with an ESP,
2 percent are equipped with an ESP followed by a wet
scrubber, and the remaining 1 percent are equipped with two
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wet scrubbers in series. The add-on control devices were
installed primarily for control of PM emissions.
The following paragraphs describe the proposed MACT
floor control technologies for new and existing kraft and
soda NDCE recovery furnaces for both PM/PM HAP and total
gaseous organic HAP control and the emission levels
achievable with each proposed MACT floor technology.
(1) PM and PM HAP MACT Floors. Properly designed and
operated ESP's used on kraft recovery furnaces routinely
achieve PM removal efficiencies of 99 percent or greater.'.
Although emission test data from recovery furnace ESP's on
PM HAP performance are limited, available data on ESP
performance indicate that those systems that achieve the
greatest PM removal show the best performance for the HAP
portion of the PM. (See Technical Support Document:
Chemical Recovery Combustion Sources at Kraft and Soda Pulp
Mills, Chapter 3; docket No. II-A-31.) Therefore, PM can be
used as a surrogate for PM HAP's.
The NSPS for kraft pulp mills requires that PM
emissions from recovery furnaces constructed, reconstructed,
or modified after September 24, 1976 be less than or equal
to 0.10 g/dscm (0.044 gr/dscf) of flue gas corrected to
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8 percent oxygen. Approximately 39 percent of NDCE recovery
furnaces are subject to the NSPS, and even more (80 percent)
reportedly achieve the NSPS limit.
Long-term (monthly) PM emission data are available for
eight NDCE recovery furnaces. Particulate matter emissions
from each of these eight NDCE recovery furnaces varied
significantly from month to month; however, PM emissions
from seven of the eight NDCE recovery furnaces consistently
met the NSPS limit of 0.10 g/dscm (0.044 gr/dscf) corrected
to 8 percent oxygen over a 4- to 6-year period.
Collectively, emissions from these seven NDCE recovery
furnaces ranged from 0.002 to 0.10 g/dscm (0.001 to
0.044 gr/dscf), corrected to 8 percent oxygen. (See State
of Washington Data Memo, docket-No. II-B-59.) Thus, the
long-term data demonstrate that NDCE recovery furnaces
equipped with ESP's can meet the NSPS level of 0.10 g/dscm
(0.044 gr/dscf) corrected to 8 percent oxygen on a long-term
basis. Because greater than 6 percent of NDCE.recovery
furnaces are capable of meeting the NSPS limit on a long-
term basis with ESP's, the proposed MACT floor PM control
technology for existing kraft and soda NDCE recovery
furnaces is an ESP capable of meeting the NSPS, which
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typically has a specific collecting area (SCA) of
100 m2/(m3/sec) (530 ft2/!, 000 acfm) . The application of the
proposed MACT floor PM control technology is represented by
a PM emission level of 0.10 g/dscm (0.044 gr/dscf) corrected
to 8 percent oxygen.
The proposed MACT floor control technology for PM HAP.
is the same as the proposed MACT floor- control technology
for PM and is represented by a PM HAP emission level of
l.OOE-03 kg/Mg (2.01E-03 Ib/ton) of black liquor solids
fired. The proposed MACT floor PM HAP emission level is
based on available test data and is equivalent to the
average PM HAP emission factor for recovery furnaces with PM
emissions that achieve the NSPS level of 0.10 g/dscm
(0.044 gr/dscf) corrected to 8 percent oxygen.
With respect to MACT for new sources, the best-
performing PM control system of the eight NDCE recovery
furnaces for which long-term PM emission data are available
is an ESP with an operating SCA between 110 and
130 m2/(m3/sec) (570 and 670 ft2/!, 000 acfm) followed by a
cross-flow, packed-bed scrubber. Monthly PM emissions data
from the NDCE recovery furnace with this control system
varied from 0.002 to 0.025 g/dscm (0.001 to 0.011 gr/dscf)
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corrected to 8 percent oxygen over a 6-year period. -Taking
the variability of the data into consideration, a PM
emission level of 0.034 g/dscm (0.015 gr/dscf) was selected
to represent the MACT floor PM emission level for new NDCE
recovery furnaces. Therefore, the proposed MACT floor PM
control technology for new kraft and soda NDCE recovery
furnaces is an ESP capable of achieving a PM emission level
of 0.034 g/dscm (0.015 gr/dscf) corrected to 8 percent
oxygen (i.e., ah ESP with a typical SCA between 110 and
130 m2/[m3/sec3 [570 and 670 ft2/!, 000 acfm] ) followed by a
packed-bed scrubber.
Although the proposed MACT floor PM control technology
for new NDCE recovery furnaces includes both the ESP and the
cross-flow, packed-bed scrubber, the scrubber was installed
as a heat recovery device and for SO2 control and is not
expected to provide much, if any, additional PM control.
Because of the high PM removal efficiencies achievable with
newer ESP's, the proposed MACT floor PM emission level of
0.034 g/dscm (0.015 gr/dscf) corrected to 8 percent oxygen
for new NDCE recovery furnaces could be achieved with the
application of the ESP alone.
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A PM-HAP emission level was not established for new
NDCE recovery furnaces because insufficient PM HAP data are
available from NDCE recovery furnaces representing MACT for
new sources.
(2) Total Gaseous Organic HAP MACT Floors. The ESP
systems applied to existing NDCE recovery furnaces conform
to one of two designs: wet ESP systems or dry ESP systems.
A wet ESP system uses unoxidized black liquor or water in
the ESP bottom or in the PM return system. A dry. ESP system
includes both a dry-bottom ESP and a dry PM return system.
Wet ESP systems that use black liquor or HAP-contaminated
water emit higher levels of gaseous organic HAP's than dry
ESP systems due to the stripping of gaseous organic HAP's
from the black liquor or HAP-contaminated water in the ESP
bottom or PM return system. Based on the available emission
data, NDCE recovery furnaces with dry ESP systems emit, on
average, approximately 72 percent less total gaseous- organic
HAP's than NDCE recovery furnaces with wet ESP systems.
Although information is available to classify almost
all (99 percent) of NDCE recovery furnace ESP's as wet- or
dry-bottom, little information is available regarding the
use of black liquor or HAP-contaminated water in the
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recovery furnace ESP PM return systems. Based on the
limited available information on ESP return systems,
approximately 5 percent of NDCE recovery furnaces are
estimated to be equipped with dry ESP systems. Because the
estimated percentage of NDCE recovery furnaces equipped with
dry ESP systems is less than 6 percent, the proposed MACT
floor control technology for total gaseous organic HAP
emissions from existing kraft and soda NDCE recovery •
furnaces is a wet ESP system, and, thus, no control of total
gaseous organic HAP's is achieved at the floor. However,.
because NDCE recovery furnaces equipped with dry ESP systems
represent the best-controlled source for total gaseous
organic HAP emissions,' the proposed MACT floor total 'gaseous
organic HAP control technology for new kraft and soda NDCE
recovery furnaces is a dry ESP system. Emission data from
three NDCE recovery furnaces equipped with dry ESP systems
indicate that a total gaseous organic HAP emission level, as
measured by methanol, of 0.012 kg/Mg (0.025 Ib/ton) of black
liquor solids fired or less is achievable. The methanol
emission level corresponds to the highest three-run averaige
obtained for a dry ESP system on an NDCE recovery furnace
plus an additional amount to account for the variability in
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the dry ESP system data set and the lack of long-term data.
Therefore, the total ga"seous organic HAP emission level, as
measured by me.thanol, associated with the proposed MACT
floor control technology (i.e., a dry ESP system) is
0.012 kg/Mg (0.025 Ib/ton) of black liquor solids fired.
b. DCE Recovery Furnace Systems. The DCE recovery
furnace system includes the recovery furnace, DCE, and the
BLO system. An estimated 83 DCE recovery furnaces are in
operation at 48 U.S. kraft and soda pulp mills. An'
estimated 46 BLO systems are in operation at these 48 pulp
mills. Of the two mills without BLO systems, one is a soda
pulp mill, and the other is a kraft pulp mill. Information
regarding the furnace type, size, and add-on control devices
and the associated BLO systems is available for
approximately 93 percent of DCE recovery furnace systems.
Like NDCE recovery furnaces, all DCE recovery furnaces
are equipped with some type of add-on control device to
reduce PM emissions from the furnace. In the case of DCE
units, 90 percent are controlled with an ESP, 8 percent are
controlled with an ESP followed by a wet scrubber, and the
remaining 2 percent-are controlled with two ESP's in series.
As with NDCE recovery furnaces, MACT floor.control
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technologies for DCE recovery furnace systems were selected
for both PM/PM HAP and total gaseous organic HAP emissions.
The following paragraphs describe the proposed MACT floor
control technologies for new and existing kraft and soda DCE
recovery furnace systems and the emission levels achievable
with each proposed MACT floor technology.
(1) PM and PM HAP MACT Floors. As discussed above for
NDCE recovery furnaces, properly designed and operated ESP's
used on kraft recovery furnaces routinely achieve PM removal
efficiencies of 99 percent or greater. Using installation
dates to determine NSPS applicability, three DCE recovery
furnaces (i.e., 4 percent of the DCE recovery furnace
population) are subject to the NSPS emission limit of'
0.10 g/dscm (0.044 gr/dscf) corrected to 8 percent oxygen
for kraft recovery furnaces. Long-term (monthly) PM
emission data are available for an additional four DCE
recovery furnaces that are not subject to the NSPS but have
consistently met the NSPS emission level of 0.10 g/dscm
(0.044 gr/dscf) corrected to 8 percent oxygen over a 3- to
6-year period, even though PM emissions from each of these
four DCE recovery furnaces varied significantly from month
to month. Collectively, the PM emissions from these four
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DCE recovery furnaces varied from 0.011 to 0.10 g/dscra
(0.005 to 0.044 gr/dscf) corrected to 8 percent oxygen over
the 3- to 6-year period. (See State of Washington Data
Memo; docket No. II-B-59.) The combination of those DCE
recovery furnaces subject to the NSPS and those for which
data show an ability to achieve the NSPS level on a
long-term basis represent a total of seven DCE recovery
furnaces, or 9 percent of the DCE recovery furnace popula-
tion.
Because greater than 6 percent of DCE recovery furnaces
are capable of meeting the NSPS PM limit on a long-term
basis with ESP's, the proposed MACT floor PM control
technology for existing kraft and soda DCE recovery furnace
systems is an ESP capable of meeting the NSPS, which
typically has an SCA of 90 m2/ (m3/sec) (430. ft2/!, 000 acfm) .
The application of the proposed MACT floor PM control
technology is represented by a PM emission level of
0.10 g/dscm (0.044 gr/dscf) corrected to 8 percent oxygen.
The proposed MACT floor control technology for PM HAP
is the same as the proposed MACT floor control technology
for-PM and is represented by a PM HAP emission level of
l.OOE-03 kg/Mg (2.01E-03 Ib/ton) of black liquor solids
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fired. As with existing NDCE recovery furnaces, the
proposed MACT floor PM HAP emission level is equivalent to
the average PM HAP emission factor for kraft and soda'
recovery furnaces with PM emissions that achieve the NSPS
level of 0.10 g/dscm (0.044 gr/dscf) corrected to 8 percent
oxygen. :
The best-performing PM control system for both NDCE and
DCE recovery furnaces is an ESP with an operating SCA
between 110 and 130 m2/(m3/sec) (570 and 670 ft2/!, 000 acftn)
followed by a cross-flow, packed-bed scrubber. Monthly PM
emissions data from the recovery furnace with this control
system varied from 0.002 to 0.025 g/dscm (0.001 to
0.011 gr/dscf) corrected to 8 percent oxygen over a 6-year
period. Taking the variability of the data into
consideration, a PM emission level of 0.034 g/dscm
(0.015 gr/dscf) was selected to represent the MACT floor PM
emission level for new DCE recovery furnaces. Therefore,
the proposed MACT floor PM control technology for all new
kraft and soda DCE recovery furnaces is an ESP capable of
achieving a PM emission level of 0.034 g/dscm
(0.015 gr/dscf) corrected to 8 percent oxygen (i.e., an ESP
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with a typical SCA between 110 and 130 m2/ [m3/sec] [570 and
670 ft2/!,000 acfm]) followed by a packed-bed scrubber.
Although the proposed MACT floor PM control technology
for new kraft and soda DCE recovery furnaces includes both
the ESP and the cross-flow, packed-bed scrubber, the
scrubber was installed as a heat recovery device and for S02
control and is not expected to provide much, if any,
additional PM control. Because of the high PM removal
efficiencies achievable with newer ESP's, the proposed MACT
floor PM emission level of 0.034 g/dscm (0.015 gr/dscf)
corrected to 8 percent oxygen for new DCE recovery furnaces
could be achieved with the application of the ESP alone.
The EPA is not proposing a MACT floor PM HAP emission
level for new kraft and soda DCE recovery furnaces for the
same reason stated above for new NDCE recovery furnaces.
(2) Total Gaseous Organic HAP MACT Floors. Four of
the estimated 46 BLO systems in operation are pipeline
molecular oxygen-based systems, which have no emission
points. No emission data are available from DCE' recovery
furnaces with molecular oxygen BLO systems for comparison
with DCE recovery furnaces with air-based BLO systems.
Therefore, the effect of molecular oxygen BLO systems on
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total emissions from the DCE recovery furnace system is
uncertain. With air-based BLO systems, gaseous organic
HAP's are stripped from the black liquor and emitted to the
atmosphere as the air bubbles and black liquor make qontact.
Unlike air-based systems, molecular oxygen systems use pure
oxygen, and, thus, no diluents are introduced that could
strip organic compounds from1 the black liquor; consequently,
organic compounds not released from the black liquor during
the oxidation process could be subsequently stripped, in
theory, from the oxidized black liquor when the black liquor
enters the direct contact evaporator. For this reason,
molecular oxygen BLO systems are not viewed by the Agency as
a control option for DCE recovery furnace systems.
The gaseous organic HAP emissions from 2 of the ;
estimated 42 air-based BLO systems are controlled via
incineration in power boilers; the remainder are
uncontrolled. However, the two air-based BLO units with
controlled emissions represent less than 6 percent of DCE
recovery furnace systems. Therefore, the proposed MACT
floor for total gaseous organic HAP control for existing
kraft and soda DCE recovery furnace systems is no control.
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The DCE recovery furnace systems emit more gaseous
organic HAP's than NDCE recovery furnaces because more
opportunities exist for gaseous organic HAP compounds to be
stripped from the black liquor. .In DCE systems, gaseous
organic HAP compounds can be stripped from the black liquor
in the BLO system, the DCE, and the ESP system. Based on
the available emission data, NDCE recovery furnaces with dry
ESP systems emit approximately 93 percent less total gaseous
organic HAP's than DCE recovery furnace systems.
The NDCE recovery furnaces with dry ESP systems also
have lower' TRS emissions compared to DCE recovery furnace
systems. The need for TRS emission reductions and the need
for additional recovery furnace capacity have resulted in
mills converting older and smaller DCE units into larger
NDCE units. Approximately 24 percent of the existing NDCE
recovery furnaces are converted DCE recovery furnaces. For
these reasons, and also because NDCE recovery furnaces are
more energy efficient than DCE recovery furnaces, all new
recovery furnace installations are of the NDCE design.
Because of its lower HAP emission potential, an NDCE
recovery furnace equipped with a dry ESP system was selected
as the MACT floor total gaseous organic HAP control .
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technology for all new kraft and soda NDCE recovery furnaces
and DCE recovery furnace systems. This proposed MACT floor
control technology is capable of achieving a total gaseous
organic HAP emission level, as measured by methanol, of
0.012 kg/Mg (0.025 Ib/ton) of black liquor solids fired.
c. Lime Kilns. An estimated 192 lime kilns operate; at
124 U.S. kraft and soda pulp mills. Information regarding
the lime kiln type, size, and add-on control devices is
available for approximately 85 percent of these lime kilns.
All of the add-on control systems in place on lime kilns are
for the control of PM or TRS emissions. No add-on controls
designed to remove gaseous organic HAP's are appliedjto lime
kilns. ' I
Gaseous organic HAP emissions from lime kilns are
primarily attributable to the use of HAP-contaminated
process waters in the lime mud washers and lime kiln
scrubbers. Therefore, gaseous organic HAP emissions ifrom
lime kilns can be minimized by reducing the HAP content of
process waters used in the lime mud washers and scrubbers.
These process waters are being regulated as part of the
final NESHAP for noncombustion sources at pulp and paper
mills. Therefore, no MACT floor has been established for
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total gaseous organic HAP's for new and existing kraft and
soda lime kilns as part of this proposed NESHAP. The
following paragraphs describe the proposed MACT floor PM/PM
HAP control•technologies and the associated emission levels
for existing and new kraft and soda lime kilns.
Particulate matter emissions from most (90 percent) of
the lime kilns are controlled by wet scrubbers. Venturi
scrubbers are the most common type of wet scrubber in use on
lime'kilns. Particulate matter emissions, from the remaining
10 percent of lime kilns are controlled by ESP's (9 percent)
or the combination of an ESP and wet scrubber (1 percent).
Properly designed and operated venturi scrubbers and ESP's
used on kraft lime kilns are capable of reducing PM
emissions by greater than 99 percent.
The NSPS for kraft pulp mills requires that PM
emissions from gas-fired lime kilns constructed,
reconstructed, or modified after September 24, 1976 be less
than or equal to 0.15 g/dscm (0.067 gr/dscf) of flue gas
corrected to 10 percent oxygen. Approximately 19 percent of
lime kilns are subject to the NSPS limit for gas-fired lime
kilns, and even more (i.e., 64 percent of all lime kilns,
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including oil-fired 'lime kilns) have reported average PM
emissions less than the gas-fired NSPS limit.
Long-term (monthly) PM emission data are available for
four gas-fired lime kilns that are subject to the NSPS PM
limit for gas-fired lime kilns. No long-term data are
available for oil-fired lime kilns. Two of the four lime
kilns for which long-term PM emission data are available are
equipped with venturi scrubbers, and two are equipped with
ESP's. Particulate matter emissions from the four lime
kilns varied from 0.002 to 0.15 g/dscm (0.001 to
0.067 gr/dscf) corrected to 10 percent oxygen over a 4- to
7-year period. The long-term data demonstrate that existing
lime kilns equipped with either venturi scrubbers or ESP's
can meet an emission level of 0.15 g/dscm (0.067 gr/dscf)
corrected to 10 percent oxygen on a long-term basis.
Because greater than 6 percent of lime kilns are capable of
meeting the gas-fired NSPS limit on a long-term basis-with
venturi scrubbers or ESP's, the proposed MACT floor control
technology for existing kraft and soda lime kilns is either
a venturi scrubber or an ESP. The application of these
proposed MACT floor PM control technologies is represented
by a PM emission level of 0.15 g/dscm (0.067 gr/dscf)
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corrected to 10 percent oxygen. The proposed MACT floor
control technology for PM HAP is the same as the proposed
MACT floor control technology for PM and is•represented by a
PM HAP emission level of 6.33E-03 kg/Mg (1.27E-02 Ib/ton) of
CaO produced. The proposed MACT floor PM HAP emission level
is equivalent to the average PM HAP emission factor for lime
kilns with outlet PM emissions that achieve the NSPS level
of 0.15 g/dscm (0.067 gr/dscf) corrected to 10 percent
oxygen.
Of the four lime kilns for which long-term PM emission
data are available, the best-performing PM control system is
an ESP with an operating SCA of 220 m2/(m3/sec)
(1,120 ft2/!,000 acfm), which is substantially higher than
the typical SCA. for an ESP designed to meet the NSPS (i.e.,
90 m2/ [m3/sec] [460 ft2/!, 000 acfm].) ... The monthly PM
emissions from the best-performing lime kiln varied from
0.002 to 0.018 g/dscm (0.001 to 0.008 gr/dscf) corrected to
10 percent oxygen over a 7-year period. To account for the
variability in .the data, a PM emission level of 0.0-23 g/dscm
(0.010 gr/dscf) was selected to represent the MACT floor PM
emission level for new lime kilns. Therefore, the proposed
MACT floor PM HAP control technology for new kraft and soda
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108
lime kilns is an ESP capable of achieving a PM emission
level of 0.023 g/dscm (0.010 gr/dscf) corrected to
10 percent oxygen (i.e., an ESP with a typical SCA of
220 tn2/[m3/sec] [1,120 ft2/!, 000 acfm] ) .
A MACT floor PM HAP emission level was not established
for new lime kilns for the same reasons stated above for new
NDCE recovery furnaces.
d. Smelt Dissolving Tanks. An estimated 227 SDT's
operate at 124 U.S. kraft and soda pulp mills. Information
regarding the SDT size and add-on control devices is
available for approximately 83 percent of the SDT's. The
add-on control systems in place on SDT's are for control of
PM emissions. No add-on controls designed to remove gaseous
organic HAP's are applied to SDT's.-
As discussed above for lime kilns, gaseous organic HAP
emissions from SDT's are primarily the result of the use of
HAP-contaminated process waters. The HAP-contaminated
process waters are typically used in the SDT scrubbers as
makeup water to the SDT. Therefore, gaseous organic HAP
emissions from SDT's can be minimi-zed by reducing the HAP
content of process waters used in the SDT and SDT scrubber.
However, as stated above for lime kilns, the control of HAP
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109
emissions from process waters is being regulated as part of
the final NESHAP for noncombustion sources at pulp and paper
mills. Therefore, no MACT floor has been established for
total gaseous organic HAP emissions for new and existing
kraft and soda SDT's as part of this proposed NESHAP.
Particulate matter emissions from most (87 percent) of
the SDT's are controlled by wet scrubbers. Particulate
matter emissions from the majority of the remaining SDT's
are controlled-by-mist eliminators. Based on the available
performance data for. wet scrubbers and mist eliminators
installed on SDT's, wet scrubbers are more effective at
controlling PM emissions from SDT's than mist eliminators.
(See Technical Support Document: Chemical Recovery
Combustion Sources at Kraft and Soda Pulp Mills, Chapter 3;
docket No. II-A-31.) Properly designed wet scrubbers used
on kraft SDT's are,capable of reducing PM emissions by
greater than 99 percent.
The NSPS for kraft pulp mills require that PM emissions
from SDT's that are constructed, modified, or reconstructed
after September 24, 1976 be less than-0.10 kg/Mg
(0.20 Ib/ton) of black liquor solids fired. Approximately
29 percent of SDT's are subject to the NSPS PM limit, and
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110
even more (75 percent) have reported average PM emissions
less than the NSPS PM limit. Although no long-term PM
emission data are available for SDT's equipped with wet
scrubbers that are subject to the NSPS limit of 0.10 kg/Mg
(0.20 Ib/ton) of black liquor solids fired, the prevalence
of wet scrubbers on SDT's and the high PM removal
efficiencies achieved with this.technology are sufficient to
establish wet scrubbers as the proposed MACT floor PM
control technology for existing kraft and soda SDT's.' The
application of this control technology is represented by a
PM emission level of 0.10 kg/Mg (0.20 Ib/ton) of black
liquor solids fired. The proposed MACT floor control
technology for PM HAP is the same as the proposed MACT floor
control technology for PM and is represented by a PM HAP
emission level of 6.20E-05 kg/Mg (1.24E-04 Ib/ton) of black
liquor solids fired. The proposed MACT floor PM HAP
emission level is equivalent to the average PM HAP emission
factor for SDT's with outlet PM emissions that achieve the
NSPS PM level of 0.10 kg/Mg (0.20 Ib/ton) of black liquor
solids fired.
Long-term (monthly) PM emission data are available for
three SDT's equipped with wet scrubbers designed to meet a
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Ill
PM permit limit (0.06 kg/Mg [0.12 Ib/ton] of black liquor
solids fired) that is more stringent than the NSPS. The
high-efficiency wet scrubbers installed on these three SDT's
represent the best-performing PM control systems installed
on kraft and soda SDT's. Collectively, monthly PM emissions
from these three SDT's varied from 0.0045 to 0.055 kg/Mg
(0.009 to 0.11 Ib/ton) of black liquor solids fired over a
2- to 6- year period. (See State of Washington Data Memo,
docket No. II-B-59.) .The long-term data demonstrate that
SDT's equipped with high-efficiency wet scrubbers can
achieve' a maximum outlet PM level of 0.06 kg/Mg
(0.12 Ib/ton) of black liquor solids fired on a long-term
basis. Therefore, the proposed MACT floor PM HAP control
technology for new kraft and soda SDT's is a high-efficiency
wet scrubber capable of achieving a PM emission level of
0.06 kg/Mg (0.12 Ib/ton) of black liquor solids fired.
*
2. MACT Floors--Sulfite Pulp Mills
i
An estimated 21 combustion units operate at sulfite
pulp mills. Information regarding the chemical recovery
equipment and add-on control devices is available for
approximately 95 percent of these combustion units. Because
there are less than 30 sulfite combustion units, the MACT
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112
floor for existing sources is based on the 5 best-performing
sources. Thirteen of the 21 sulfite combustion units
(62 percent) are equipped with fiber-bed demister systems.
The remainder of the combustion units are equipped with
venturi scrubbers or packed-bed scrubbers. These add-on
control devices were installed on sulfite combustion .units
for PM control and additional SO2 control. All sulfite
combustion units are equipped'with absorption towers prior
to the PM control device to recover SO2 for reuse in the
pulping process.
Long-term PM emission data are available for two
sulfite combustion units equipped with fiber-bed demister
systems. Based on these long-term data and additional long-
term data for sulfite combustion units equipped with wet
scrubbers, fiber-bed demister systems are more effective
than wet scrubbers at controlling PM emissions from sulfite
4
combustion units. Monthly PM emission data from the .two
sulfite combustion units equipped with fiber-bed demister
systems ranged from 0.005 to o'.OSS g/dscm (0.002 to
0.038 gr/dscf) corrected to 8 percent oxygen over a 6- to
7-year period. Because the fiber-bed demister system
represents the best-performing control technology and at
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113
least five sources are equipped with fiber-bed demister
systems, this technology was selected to represent the
proposed MACT floor control technology for existing sulfite
combustion units. To account for variability in the data, a
PM emission level of 0.092 g/dscm (0.040 gr/dscf) corrected
to 8 percent oxygen was selected to represent the MACT floor
PM emission level for existing sulfite combustion units.
Monthly PM emission data from the best-performing
sulfite combustion unit equipped with a fiber-bed demister
system ranged from 0.009 to 0.039 g/dscm (0.004 to
0.017 gr/dscf)' corrected to 8 percent oxygen over a 6-year
period. This sulfite combustion unit also is equipped with
a wet scrubber between the SO2 absorption towers and the
fiber-bed demister system. The scrubber was added to the
system for additional PM and SO2 control. Because the best-
performing source is equipped with a wet scrubber and fiber-
bed demister system, the combination of these technologies
was selected to represent the proposed MACT floor control
technology for new sulfite combustion units. To account for
the variability in the data, a PM emission level of
0.046 g/dscm (0.020 gr/dscf) corrected to 8 percent oxygen
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114
i
was selected to represent the MACT floor PM emission level
for new sulfite combustion units.
3. MACT Floors—Stand-Alone Semichemical Pulp Mills
An estimated 14 chemical recovery combustion units
operate at 13 U.S. stand-alone semichemical pulp mills.
Information regarding the design and operation of chemical
recovery combustion units is available for all of these
units. Although chemical recovery combustion units at
stand-alone semichemical pulp mills are equipped with a
variety of PM control devices, insufficient PM data and no
PM HAP data are available to establish MACT floors for PM or
PM HAP. In addition, none of the existing semichemical
mills are currently controlling gaseous organic HAP
emissions from semichemical combustion sources. Therefore,
no control of total gaseous organic HAP emissions is
achieved at the MACT floor for existing or new sources.
However, the Agency has selected a beyond-the-floor
option to represent MACT for gaseous organic HAP control for
existing and new semichemical combustion sources. The
beyond-the-floor option is based on the use of an RTO'
preceded by a wet ESP. (A wet ESP or other PM control
device is necessary because' the RTO requires a high degree
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115
of PM control for proper operation.) Pilot study results at
a stand-alone semichemical mill indicate that an RTO is
well-suited to reducing gaseous organic HAP emissions from
fluidized-bed reactors, which emit the highest known
quantities of HAP's of the combustion technologies currently
in use at semichemical pulp mills. The semichemical mill
that conducted the pilot study is currently installing a
full-scale RTO based on the results of the pilot study.
During the pilot study, the RTO reduced THC emissions
from the mill's fluidized-bed reactor by.an average of
97 percent. However, because the RTO has not yet been
demonstrated full-scale at a semichemical mill, EPA
estimated the total ga'seous organic HAP emission level that
corresponds to MACT using the average THC emission reduction
(90 percent) achieved during the pilot study test run with
the lowest level of control. The estimated 90 percent THC
emission reduction was applied to the average uncontrolled
THC emissions (measured as carbon) from a fluidized-bed
reactor. Based on the results of the calculation, the
application of an RTO preceded by a wet ESP is estimated to
be representative of either a total gaseous organic HAP
emission level of 1.49 kg/Mg (2.. 97 Ib/ton) of black liquor
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116 ;
solids fired, or a 90 percent reduction in. total gaseous
organic HAP emissions. (Total gaseous organic HAP's are
measured as THC, as carbon, in both cases.)
F. Discussion o£ Regulatory Alternatives
The proposed standards were selected based on a review
of the regulatory alternatives developed for the affepted
sources. Table 3 presents the regulatory alternatives
examined for existing affected sources at kraft and soda
pulp mills; Tables 4 and 5 present the regulatory
alternatives for existing affected sources at sulfitel and
stand-alone semichemical pulp mills, respectively. For
existing affected sources, regulatory alternative I (RA I)
represents the proposed MACT floor, and additional
regulatory alternatives represent beyond-the-MACT-floor
options. The regulatory alternatives are increasingly more
stringent in terms of total HAP emission reduction
requirements. The most stringent regulatory alternative
examined for existing sources is representative of MACT for
new sources. A discussion of the regulatory alternatives is
provided below.
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TABLE 3. REGULATORY ALTERNATIVES FOR EXISTING AFFECTED
SOURCES AT KRAFT AND SODA PULP 'MILLS
Regulatory
alternatives
(RA)
RA I (MACT
floor for
existing
sources)
RAII
RAIII
RAIV
(MACT floor
for new
sources)3
Basis of alternative
Recovery furnace systems
NDCE
NDCE recovery
furnace with ESP,
NDCE recovery
furnace with ESP,
NDCE recovery
furnace with dry ESPt
system
NDCE recovery
furnace with dry ESP2
system and packed-bed
scrubber
DCE
DCE recovery furnace
with ESPj
DCE recovery furnace
with ESP; plus BLO
vent controlled by
incineration
NDCE recovery
furnace with dry ESP,
system
NDCE recovery
furnace with dry ESP2
system and packed-bed
scrubber
Smelt
dissolving
tanks
Wet
scrubber,
Wet
scrubber.
Wet
scrubber,
Wet
scrubber2
Lime
kilns
ESP, or
wet
scrubber.
ESP, or
wet
scrubber,
ESP, or
wet
scrubber.
ESP2
aTighter PM control is achieved for new sources through the use of a more efficient ESP design
(ESP2) or scrubber design (wet scrubber2) than that used under regulatory alternatives I through III
(ESP, or wet scrubber,) for existing sources.
TABLE 4. REGULATORY ALTERNATIVES FOR EXISTING AFFECTED
SOURCES AT SULFITE PULP MILLS
Regulatory alternatives (RA)
Basis of alternative
RA I (MACT floor for existing
sources)
Fiber-bed demister system
RA II (MACT floor for new sources)
Wet scrubber followed by fiber-bed demister system
TABLE 5. REGULATORY ALTERNATIVES FOR EXISTING AFFECTED
SOURCES AT SEMICHEMICAL' PULP MILLS
Regulatory alternatives (RA)
Basis of alternative
RA I (MACT floor for existing and
new sources)
No control
RA II (Beyond-the-MACT floor for
existing and new sources)
Wet ESP followed by regenerative thermal oxidizer
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118
1. Kraft and Soda Pulp Mills ;
As shown in Table 5, four regulatory alternatives were
considered for MACT selection for affected sources at kraft
and soda pulp mills. The first regulatory alternative
(RA I) represents the proposed MACT floor for existing
affected sources, and the other three alternatives (RA II,
RA III, and RA IV) represent beyond-the-MACT-floor options.
Each of these regulatory alternatives is discussed below by
emission point. :
a. NDCE Recovery Furnaces. For NDCE recovery
furnaces, the regulatory alternatives are based on two
levels of PM HAP control and two levels of total gaseous
organic HAP control, as measured by methanol. Under RA I
(proposed MACT floor for existing sources), PM HAP emissions
would be controlled through the application of an ESP with a
typical operating SCA of 100 m2/ (m3/sec)
(530 ft2/!, 000 acfm) ; the ESP would reduce PM HAP emissions
by greater than 99 percent. ;
The regulatory alternatives RA II and RA III are based
on the same PM HAP control equipment specifications for the
NDCE recovery furnace as RA I (the proposed MACT floor);
therefore, no further reduction in PM HAP emissions would be
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119
achieved under RA II and RA III than that achieved at the
floor. However, under RA III, total gaseous organic HAP
emissions would be controlled to levels beyond the proposed
MACT floor through the application-of a dry ESP system
(i.e., a dry-bottom ESP with a dry PM return system). The
use of a dry ESP system would result in a reduction'in total
gaseous organic HAP emissions from those mills currently
using wet ESP systems (i.e., wet-bottom ESP's or dry-bottom
ESP's with wet PM return systems). Wet ESP systems emit
greater quantities of gaseous organic HAP's because these
compounds are stripped from the black liquor in the bottom
of the ESP and in the PM return system.
The most stringent beyond-the-floor regulatory
alternative (RA IV) combines the conversion of the ESP
system with more stringent PM HAP control requirements for
the furnace. The more stringent PM HAP control would be
obtained through the application of an ESP followed by a
packed-bed scrubber; the typical operating SCA of the ESP
would be between 110 and 130 m2/(m3/sec) (570 and
670 ft2/!, 000 acftn)'. Although the packed-bed scrubber is
capable of reducing HC1 emissions from the NDCE recovery
furnace by as much as 99 percent, as stated in
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120
section IV.E.I.a of this preamble, the ESP could be used
alone to meet the PM emission limit for new NDCE recovery
furnaces because the scrubber removes little, if any,:of the
PM remaining in the gas stream exiting the ESP. Because the
PM HAP control costs for RA IV are based on an ESP followed
by a packed-bed scrubber, those costs are overstated.
Regulatory alternative IV is representative of the best-
controlled similar source for NDCE recovery furnaces.
b. DCE Recovery Furnace Systems. For DCE recovery
furnace systems, the regulatory alternatives are based on
two levels of PM HAP control and three levels of total
gaseous organic HAP control, as measured by methanol. Under
the proposed MACT floor regulatory alternative RA I, PM HAP
emissions would be reduced through the application of an ESP
with a typical operating SCA of 90 m2/(m3/sec) :
(430 ft2/!,000 acfm). [
The beyond-the-floor regulatory alternative RA II is
based on the same PM HAP control equipment specifications
for the DCE recovery furnace as RA I; however, total gaseous
organic HAP emissions also would be reduced by controlling
the vent gases from air-based BLO systems to a beyond-the-
floor level via incineration. The use of an incineration
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121
device such as a power boiler or thermal oxidizer could
achieve total gaseous organic HAP emission reductions of
98 percent or greater from air-based BLO systems, which.
would translate to a 38'percent reduction of total gaseous
organic HAP emissions from the entire DCE recovery furnace
system.
The beyond-the-floor regulatory alternative RA III is
based on the conversion of the DCE recovery furnace to an
NDCE recovery furnace equipped with a dry ESP system with a
typical operating SCA "of 100 m2/(m3/sec)
(530 ft2/l,000 acfm). The conversion of the DCE recovery
.furnace would reduce total gaseous organic HAP emissions
from the DCE recovery furnace system by approximately
93 percent. No further reduction in PM HAP emissions would
be achieved under. RA III than that achieved at the floor
(RA I) for DCE recovery.furnaces.
The most stringent beyond-the-floor regulatory
alternative-.(RA IV) combines the conversion of the DCE
recovery furnace with more stringent PM HAP control
requirements for the furnace. The more stringent PM HAP
control requirements are based on an ESP. with a typical
operating SCA between 110 and 130 m2/ (m3/sec) (570 and
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122
670 ft2/!,000 acfm) followed by a packed-bed scrubber.
Although the packed-bed scrubber is capable of reducing HCl
emissions from the DCE recovery furnace by as much as^
99 percent, as stated in section IV.E.I.a of this preamble,
the ESP could be used alone to meet the PM emission limit
for new recovery furnaces because the scrubber removes
little, if any, of the PM remaining in the gas stream
exiting the ESP. Because the PM HAP control costs for RA IV
are based on an ESP followed by a packed-bed scrubber, those
costs are overstated. Regulatory alternative IV is ,
representative of the best-controlled similar source for DCE
recovery furnace systems.
c. Smelt Dissolving Tanks. For SDT's, the regulatory
alternatives are based on two levels of PM HAP control.
Regulatory alternatives I through III are based on the use
of a wet scrubber designed to meet the NSPS PM emission
level. The beyond-the-floor regulatory alternative RA IV is
based on the use of a high-efficiency wet scrubber designed
to reduce PM emissions from SDT's. Based on current
information, no controls more stringent than the use of
high-efficiency wet scrubbers are being applied to SDT's.
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d. Lime Kilns. Two PM HAP control levels were
considered for.lime kilns. Under regulatory alternatives I
through III, the PM control level is based on the-level
achievable with a wet scrubber or an ESP designed to meet
the NSPS. Under the beyond-the-floor regulatory alternative
RA IV, increased PM control is obtained through the
application of an ESP with a typical operating SCA of
220 m2/(m3/sec) (1,120 ft2/!, 000 acfm) .
2. Sulfite Pulp Mills
As shown in Table 4, two regulatory alternatives were
considered for sulfite combustion units. Both of these
alternatives would reduce PM HAP emissions from the sulfite
combustion unit. Regulatory alternative I represents the
proposed MACT floor for existing sulfite combustion units
and is based on the use of a fiber-bed demister system.
Regulatory alternative II is more stringent than the
proposed MACT floor option and is based on the use of a wet
scrubber followed by a fiber-bed demister system.
3. Stand-alone Semichemical Pulp Mills
•As shown in Table 5, two regulatory alternatives for
total gaseous organic HAP's were considered for combustion
sources at stand-alone semichemical pulp mills. Regulatory
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124
alternative I represents the MACT floor for existing;
sources, which is no control. Regulatory alternative II is
more stringent than the MACT floor option and is based on
the use of a wet ESP followed by ah RTO to reduce HAP
emissions from the semichemical combustion units.
G. Selection of Proposed Standards for Existing and
New Sources .
1. Existing Sources
The proposed standards for each emission point are
based on the emission level achievable when MACT is applied
to that source. For existing sources, MACT was determined
by evaluating the regulatory alternatives presented in
Tables 3 through 5. The Agency selected RA I, or the MACT
i
floor alternative, as MACT for existing sources at kraft,
soda, and sulfite pulp mills. The decision to select RA I
was based on a comparison of the costs and benefits of the
regulatory alternatives for existing sources at kraft, soda,
and sulfite pulp mills. The Agency concluded that the
benefits of additional controls beyond the MACT floor for
kraft, soda, and sulfite pulp mills do hot outweigh the high
capital costs (shown in Tables 6 and 7).
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125
TABLE 6. NATIONWIDE COSTS ASSOCIATED WITH REGULATORY
ALTERNATIVES FOR KRAFT AND SODA AFFECTED SOURCES
Regulatory alternatives (RA)
RAI
(MACT floor for existing sources)
RAII
(Beyond the floor for existing
sources)
RAIII
(Beyond the floor for existing
sources)
RAIV
(Beyond the floor for existing
sources; MACT floor for new
sources)
Total capital
investment, $
219,000,000
343,000,000
1,450,000,000
2,080,000,000
Total annual cost, $/yr
23,000,000
57,000,000
64,400,000
152,000,000
TABLE 7. NATIONWIDE COSTS ASSOCIATED WITH REGULATORY
ALTERNATIVES FOR SULFITE AFFECTED SOURCES
Regulatory alternatives (RA)
RAI
(MACT floor for existing sources)
RAII
(Beyond the floor for existing
sources; MACT floor for new
sources)
Total capital
investment, $
11,400,000
19,600,000
Total annual cost, $/yr
5,120,000
8,770,000
TABLE 8. NATIONWIDE COSTS ASSOCIATED WITH REGULATORY
ALTERNATIVES FOR SEMICHEMICAL AFFECTED SOURCES
Regulatory alternatives (RA)
RAI
(MACT floor for existing and new
sources)
RAII
(Beyond the floor for existing and
new sources)
Total capital
investment, $
0
28,100,000
Total annual cost, $/yr
0
6,860,000
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126 -
.The Agency selected RA II, or the beyond-the-flopr
alternative, as MACT for existing sources at stand-alone
semi chemical pulp mills. The decision to select RA II was
based on (1) the suitability of RTO technology for use with
fluidized-bed reactors, which emit the highest quantities of
gaseous organic HAP's of the chemical recovery combustion
technologies currently in use at stand-alone semichemical
pulp mills; (2) the plans of one semichemical mill to
install a full-scale RTO system (preceded by a wet ESP)
following a successful RTO pilot study; and (3) the low
cost-effectiveness value associated with a combination wet
ESP and RTO. (The cost-effectiveness value is less than
$2,800/Mg HAP's [$2,500/ton HAP's] based on conservative
cost estimates.) Table 8 presents the costs associated with
the regulatory alternatives for existing sources at stand-
alone semichemical pulp mills.
Information on the costs and environmental impacts of
each alternative can be found in the memorandum entitled
"Nationwide Costs, Environmental Impacts, and Cost- :
Effectiveness of Regulatory Alternatives for Kraft, Soda,
Sulfite, and Semichemical Combustion Sources" (docket
No. II-B-63). The economic impacts of each alternative are
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127
discussed in "Economic Analysis for the National Emission
Standards for Hazardous Air Pollutants for Source Category:
Pulp and Paper Production; Effluent Limitations Guidelines,
Pretreatment Standards, and New Source Performance
Standards: Pulp, Paper, and Paperboard Category--Phase I"
(docket No. II-A-32), hereafter referred to as the "Economic
Analysis Document."
2. New Sources
The most stringent regulatory alternatives examined for
existing sources (RA IV for kraft and soda pulp mills; RA II
for sulfite pulp mills; and RA II for stand-alone
semichemical pulp mills) are representative of MACT for new
sources. The proposed standards are equivalent to the
.emission level achieved by the application of MACT. The
proposed new source MACT for kraft and soda pulp mills is
represented by (1) an NDCE recovery furnace equipped with a
dry ESP system with an SCA between 110 and 130 m2/(m3/sec)
(570 and 670 ft2/!, 000 acfm) followed by a packed-bed
scrubber for both NDCE and DCE recovery furnaces, (2) a wet
scrubber designed to meet a PM emission limit of 0.06 kg/Mg
(0.12 Ib/ton) of black liquor solids fired for SDT's, and
(3) an ESP with an SCA of 220 m2/(m3/sec)
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128
(1,120 ft2/!,000 acfm) for lime kilns. The proposed new
source MACT for sulfite combustion units is represented by a
wet scrubber followed by a fiber-bed demister system. The
proposed new source MACT for'semichemical combustion units
is represented by a wet ESP followed by an RTO.
H. Selection of Format of the Standards ;
1. PM HAP Standards for Kraft and Soda Pulp Mills
In selecting the type and format of the proposed PM HAP
standard for kraft and soda pulp mills, the Agency took into
consideration the fact that the HAP fraction of the PM
emitted was small (approximately 0.25 percent).
Consequently today's proposed standards provide owners and
operators of existing affected sources at kraft and soda
pulp mills several alternatives for meeting the proposed PM
HAP standards. Owners or operators of .existing affected
sources would be allowed to comply with either the PM or the
PM HAP emission limit set for each source. In addition, as
an alternative to meeting either the PM or PM HAP emission
limits for each existing affected' source, the proposed rule
would allow owners or operators to comply with the PM_ HAP
standards by using a bubble compliance alternative that
groups PM or PM HAP emissions from all existing sources
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129 •
together. Under the proposed bubble compliance alternative,
owners or operators could control PM or PM HAP emissions
more than required at one emission point, where control.
costs are relatively low, in return for a comparable
relaxation of controls at a second emission point where
control costs are higher. This approach allows the owner or
operator the maximum degree of flexibility in developing the
PM or PM HAP control' strategy for existing sources in the
chemical recovery area while reducing HAP emissions to the
same levels that would be achieved through the application
of MACT for each affected source.
The proposed bubble compliance alternative only applies
to existing sources at kraft and soda pulp mills- New
sources must meet the applicable PM emission limits proposed
for new sources. The use of the bubble was limited to
existing sources because (1) new sources historically have
been held to stricter standards than existing sources, and
(2) state-of-the-art equipment design and add-on, controls
can'be integrated and installed most cost effectively during
construction of new sources.
The PM emission limits are provided in units of g/dscm
(gr/dscf) for kraft recovery furnaces and lime kilns and
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130
units of kg/Mg (Ib/ton) of black liquor solids fired for
SDT's to be consistent with the NSPS for kraft pulp mills.
The PM HAP emission rates are provided in units of kg/Mg
(Ib/ton) of black liquor solids fired because of the low PM
HAP concentrations present in exhaust gases from affected
*
sources at kraft and soda pulp mills.
2. PM Standards for Sulfite Pulp Mills
In selecting the type and format of the proposed PM
standard for sulfite pulp mills, the Agency took into
consideration the limited amount of PM HAP data available,
for sulfite combustion units. Because very little PM HAP
data are available from sulfite combustion units, PM is used
as a surrogate for PM HAP, and an alternate PM HAP standard
is not provided. In addition, because (1) emissions from
multiple sulfite combustion units at the same sulfite mill
are typically controlled by the same equipment and •
(2) sulfite combustion units are the only affected source at
sulfite mills, a "bubble" equation was not developed for
sulfite pulp mills. The PM emission limits for both new and
existing sulfite combustion units are based on available
long-term PM emission data for sulfite combustion units in
the State of Washington. The State of Washington data are
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131
expressed as PM concentrations [e.g., g/dscm (gr/dscf)],
corrected to 8 percent oxygen. Therefore, the PM emission
limits for new and existing sulfite combustion units are in
concentration units, corrected to 8 percent oxygen.
3. Total Gaseous Organic HAP Standard for Kraft and
Soda Pulp Mills
In selecting the type and format of the proposed total
gaseous organic HAP standard for new kraft and soda NDCE
recovery furnaces and DCE recovery furnace systems, the
Agency considered the following facts: (1) methanol is the
primary HAP for which emission data are available, (2) the
emission mechanism for. methanol is the same as for other
gaseous organic HAP's, and (3) emissions of methanol from
well-controlled sources are low (less than 5 ppmj .
Consequently, the Agency elected to use methanol as a
surrogate for total gaseous organic HAP's and establish a
methanol emission limit in the form of a mass emission rate
(i.e., kg/Mg [Ib/ton] of.black liquor solids fired).
4. Total Gaseous Organic HAP Standard for Stand-Alone
Semichemical Pulp Mills
In selecting the type and format of the proposed total
gaseous organic HAP standard for semichemical combustion
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sources, the Agency considered the following facts:
(1) approximately half of the affected sources at stand-
alone semichemical pulp mills would require add-on controls
to reduce HAP emissions, while the other half likely could
meet the total gaseous organic HAP limit without add-on
controls and/or could reduce HAP emissions through process
changes, and (2) emissions from semichemical combustion
units are highly variable. Therefore, the Agency elected to
allow affected sources to meet either an emission limit (in
units of kg/Mg [Ib/ton] of black liquor solids fired)'or
a percent reduction to provide flexibility and to
accommodate the expected differences in emission levels and
control strategies at stand-alone semichemical pulp mills.
The emission limit and percent reduction are both based on
measurements of THC (measured as carbon) as a surrogate for
total gaseous organic HAP's because THC data correlate with
available HAP data.
I. Selection of Monitoring Requirements
To ensure compliance with today's proposed PM HAP
standards, owners or operators- of recovery furnaces and lime
kilns equipped with ESP's would be•required to maintain
opacity levels below a specified level. Owners or operators
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of affected sources equipped with control devices other than
ESP's would be required to establish control device or
process operating parameter ranges that indicate the control
device or process is being operated and maintained in
accordance with good air pollution control practices.
Owners or operators complying with the proposed total
gaseous organic HAP limit for new kraft and soda recovery
furnaces that use an NDCE recovery. furnace with a dry ESP
system are exempt from monitoring requirements for gaseous
organic HAP's because the use of this equipment ensures
continuous compliance with the emission .limit.
Today's standards include two levels of monitoring.
Each monitoring level specifies maximum opacities (ESP's
only) and a maximum frequency with which the opacity or
monitored parameters may exceed established levels. If the
conditions of the first monitoring level are exceeded, the
owner or operator would be required to implement the
corrective actions contained in their SSM plan to bring the
operating parameter or opacity levels back to established
levels. Exceedance of the conditions of the second level
would constitute a violation of the standard. The purpose
of the two-level monitoring appproach is to prevent a
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violation from occurring by requiring the owner or operator
to correct operating parameter or opacity excursions before
the threat of a violation arises. ;
Owners or operators of kraft and soda SDT's and lime
kilns and sulfite combustion units equipped with wet '.
scrubbers would be required to establish a range .of values
for scrubber pressure drop and liquid flow rate that
indicate compliance with today's PM HAP standards. The
Agency selected the proposed monitoring parameters.for wet
scrubbers because these parameters are reliable indicators
of PM and PM HAP control device performance.
: For consistency with the NSPS for kraft pulp mills, the
Agency adopted the following requirements from the NSPS:
(1) the use of continuous opacity monitors to monitor PM
emissions from ESP's; (2) the opacity level (i.e.,
35 percent) indicating a violation of PM or PM HAP emission
limits for existing kraft and: soda recovery furnaces ;
equipped with ESP's; and (3) the maximum allowable opacity
exceedance frequency of 6 percent of the semiannual '•
reporting period. For new kraft and soda recovery furnaces,
a 6-minute average opacity level of 20 percent was selected
as the opacity level that, if exceeded for 10 consecutive
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6-minute periods, would require corrective action by the
owner or operator. An opacity level of 20 percent was
chosen because the kraft recovery furnace that represents
the new source MACT floor for PM control is subject to a
State opacity limit of 20 percent.
Although the proposed PM emission limit for existing
kraft and soda lime kilns is equivalent.to the NSPS PM
emission limit for gas-fired lime kilns, the monitoring
requirement for determining compliance with the proposed PM
emission limit is not equivalent to the NSPS monitoring
requirement. The NSPS does not include'an opacity limit for
lime kilns. Under the proposed rule, the Agency selected
20 percent as the opacity level that, if exceeded for
10 consecutive 6-minute periods, would require corrective
action by the owner or operator, and if exceeded for more
that 6 percent of any semiannual reporting period, would
constitute a violation of the standard. An opacity level of
20 percent was chosen because a number of newer existing
lime kilns equipped with ESP's are currently subject to
State opacity limits of 20 percent.
The Agency selected temperature as the operating
parameter to be monitored and recorded for sources complying
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with the total gaseous organic HAP emission standard for
semichemical combustion units through the use of an RTO
because the temperature of the RTO is an indicator of total
gaseous organic HAP control.
The Agency selected a 3-hour averaging time for
calculating monitoring parameter values for the purpose of
determining possible violations of the standard because
(1) EPA test methods referenced in today's proposed rule
require the owner or operator to perform a minimum of three
1-hour test runs, and (2) the limits of the established
range of parameter values would be based on the average
values obtained using all test data obtained during the
performance test.
J. Selection of Test Methods
The following discussion identifies the test methods
that are to be used for compliance determinations.
Test Method 5, "Determination of Particulate Emissions
from Stationary Sources" [40 CFR part 60, appendix A]--in
conjunction with either the integrated sampling techniques
of Test Method 3, "Gas Analysis for the Determination;of Dry
Molecular Weight" [40 CFR part 60, appendix A] or Test
Method 3A, "Determination of Oxygen and Carbon Dioxide
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Concentrations in Emissions from Stationary Sources" [40 CFR
part 60, appendix A]--is the selected test method for
determining compliance with the PM emission standards for
kraft and soda recovery furnaces, SDT's, and lime kilns and
sulfite combustion units. Test Method 5 was used to collect
the PM emission data that form the basis of the PM standards
proposed for kraft, soda, and sulfite combustion sources and
also is the required test method for measuring PM from
sources subject to the NSPS for kraft pulp mills.
Test Method 17, "Determination of Particulate Matter
Emissions from Stationary Sources (In-Stack Filtration
Method) ," may be used as an alternative to Test Method 5 if
a constant value of 0.009 g/dscm (0.004 gr/dscf) is added to
the results of Test Method 17 and the stack temperature is
no greater than 205°C (400°F) . Owners and operators of
sources subject to the NSPS for kraft pulp mills are allowed
to use Test Method 17 as an alternative to Test Method 5 for
demonstrating compliance with the PM standards of the NSPS,
and, therefore, today's proposed rule makes the same
allowance to be consistent with the NSPS.
Test Method 29, "Determination of Metals Emissions from
Stationary Sources" [40 CFR part 60, appendix A] is the.
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selected test method for determining compliance with the PM
HAP emission standards for kraft and soda recovery furnaces,
SDT's, and lime kilns. Test Method 29 can also be used as
an alternative to Test Method 5 for measuring PM emissions.
The PM HAP data upon which the PM HAP emission limits;for
kraft and soda combustion sources are based were collected
before Test Method 29 was proposed using a variety of•test
methods that are similar or identical to Test Method 29.
Test Method 29 collects mercury in part with impingers
filled with a solution of potassium permanganate. Because
manganese, a component of potassium permanganate, is also a
target analyte for Test Method 29, extreme caution should be
used to ensure that the potassium permanganate used to
collect mercury does not contaminate the portions of the
sample that will be analyzed for manganese. To eliminate
f
the possibility of contamination, the Agency will allow
operators or owners the option of measuring all of the
target PM HAP's, except mercury, with Test Method 29 and
1
making a separate measurement of the mercury using Test
Method 101A, "Determination of Particulate and Gaseous
Mercury Emissions from Sewage Sludge Incinerators" [40 CFR
part 61, appendix A].
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Test Method 308, "Procedure for Determination of.
Methanol Emissions from Stationary Sources" [40 CFR part 63,
appe'ndix A] is being promulgated today as part of the final
NESHAP for noncombustion sources in the pulp and paper
industry and is the test method for determining compliance
with the total gaseous organic HAP emission, limit for new
kraft and soda NDCE recovery furnaces and any new DCE
recovery furnace systems. The methanol data upon which the
total gaseous organic HAP emission limit for new kraft and
soda NDCE recovery furnaces and new DCE recovery furnace
systems is based were collected using a test method
developed by the National Council of the Paper Industry for
Air and Stream Improvement that served as the basis for Test
Method 308. Performance testing using Test Method 308 (or
any other approved test method .for methanol emissions from
kraft and soda recovery furnaces) would only be required for
those new sources that choose to comply with total gaseous
organic HAP emission limit for new kraft and soda recovery
furnaces by using equipment other than an NDCE recovery
furnace equipped with a dry ESP system.
Test Method 25A, "Determination of Total Gaseous
Organic Concentration using a Flame lonization Analyzer"
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140 i
[40 CFR part 60, appendix A] is the selected test method for
determining compliance with the total gaseous organic! HAP
emission limit for semichemical combustion units. The THC
data upon which the total gaseous organic HAP emission limit
for semichemical combustion units is based were collected
using Test Method 25A. • , .
K. Selection of Reporting and Recordkeeping
Requirements >• '
The owner or operator of any kraft, soda, sulfite or
stand-alone semichemical pulp mill subject to these
standards would be required to fulfill the reporting and
recordkeeping requirements outlined in § 63.10 of the
General Provisions. These requirements include those;
associated with startup, shutdown, or malfunctions; \
operation and maintenance records; compliance monitoring
system records; performance test data and reporting;
quarterly reports of no excess emissions; and quarterly
reports of exceedances of the emission limits. The owner or
operator of any kraft, soda,.sulfite or stand-alone
semichemical pulp mill subject to these'standards would be
required to submit quarterly reports of any exceedances of
monitored operating parameter values required under the
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proposed rule. These quarterly reports must contain the
monitored operating parameter value readings for the periods
constituting exceedances and a description and timing of
steps taken to address the cause of the exceedances.
L. . Relationship to other Regulations
This section of the preamble discusses the
interrelationship between today's proposed regulation and
other federal regulations covering pulp mills. The purpose
of this section is to document the Agency's evaluation of
pertinent rules in an.effort to minimize the burden on the
industry and enforcement authorities. The Agency is
interested in hearing from all interested parties on
specific suggestions for reducing.the overall burden of the
rule without jeopardizing the enforceability of the rules or
the Agency's overall emission reduction goals.
1. Noncombustion Source Rule and Chemical Recovery
Combustion Source Rule
As mentioned previously in this notice (See section II-
A, BACKGROUND), EPA is promulgating effluent limitations
guidelines and standards for the control of wastewater
pollutants, as well as NESHAP for noncombustion sources in
the pulp and paper industry as part of today's cluster rule.
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During the development of today's proposed chemical recovery
combustion source NESHAP, the Agency examined both the
chemical recovery combustion source rule and the i
noncombustion source rule to identify areas where the^
reporting and recordkeeping requirements of the rules,could
be minimized. Once the combustion source NESHAP has been
promulgated, any of the initial notifications requireci by
§ 63.7(b) of subpart A can be combined for both NESHAP and a
single notification submitted to the appropriate authority.
However, some reporting and recordkeeping requirements are
specific to the individual regulations because the rules
cover different emission points at the pulp mill. To
minimize the overall burden on the industry, the Agency made
an effort to ensure that today's proposed NESHAP for
chemical recovery combustion sources contains only the
minimum amount of recordkeeping necessary to demonstrate
compliance with the rule.
2. NSPS (Subpart BE of Part 60) and Chemical Recovery
Combustion Source Rule
The NSPS for kraft pulp mills and the chemical recovery
combustion source rule proposed today are closely related
because both rules cover some of the same emission points.
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As noted in section III.B of this preamble, today's proposed
rule allows the use of PM as a surrogate for PM HAP. Both
of the rules regulate PM emissions from recovery furnaces,
lime kilns, and SDT's at kraft pulp mills. In addition, the
proposed PM emission limits for existing kraft and soda
recovery furnaces, SDT's and lime kilns are the same as the
NSPS limits for kraft recovery furnaces, SDT's and gas-fired
lime kilns. However, the proposed NESHAP regulates
emissions from both new and existing affected sources, and,
therefore, would regulate emissions from affected sources
not currently impacted by the NSPS.
The PM emission limits in today's proposed rule for new
and reconstructed affected sources at kraft pulp mills are
more stringent than the NSPS PM limits. Also, today's
proposed rule provides alternate PM HAP standards for
existing affected sources. In addition, unlike the NSPS,
today's proposed rule would allow owners or operators of
existing kraft or soda pulp mills to meet an overall PM or
overall PM HAP emission limit that includes all existing
affected sources at the mill (i.e., the proposed bubble
compliance alternative). However, owners or operators that
choose to comply with the PM HAP standards of this proposed
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NESHAP by using the proposed bubble compliance alternative
must continue to comply with the NSPS for kraft pulp mills
by ensuring that existing affected sources subject to; the
NSPS continue to meet the NSPS PM limits specified for those
sources.
Today's proposed rule adopts many of the monitoring
requirements in the NSPS. (See section III.D, Monitoring
Requirements and Compliance Provisions.) Requirements
adopted from the NSPS include those specifying the !
parameters to be monitored and frequency of monitoring, the
level of opacity for existing recovery furnaces, and the
required accuracy of monitoring equipment. ,
In addition to requirements adopted from the NSPS,
today's proposed rule would require owners or operato±s of
i
control systems other than ESP's to establish ranges of
monitored parameters during initial compliance testing and
to operate control systems within the established range.
Today's proposed rule also sets intermediate opacity levels
and frequencies of exceedances of established operating
parameter ranges and opacity levels that would not indicate
a violation of the standard but that would require the owner
or operator to initiate the 'corrective actions identified in
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their SSM plan. Today's proposed rule also would require
owners or operators of new recovery furnaces or new or
existing lime kilns at kraft and soda pulp mills to monitor
opacity levels and would specify a maximum opacity level of
20 percent rather than 35 percent, as is specified in the
NSPS for kraft recovery furnaces.
The recordkeeping burden is different for the NSPS and
today's proposed rule. Under the NSPS, the monitored values
must be recorded once per shift. In today's proposed rule,
the monitored values would be required to be recorded on a
continuous basis, with the possible exception of when a
source is controlled by a device or system other than an
ESP, wet scrubber, or RTO. In such cases, the owner or
operator would be required to obtain approval from the
applicable permitting authority for a monitoring plan that
proposes less frequent monitoring.
Another area where the two rules differ is the
reporting requirements. For example, the General Provisions
to part 60 (followed in the NSPS for kraft pulp mills)
require only a 30-day prior notice before the performance
test date; however the General Provisions to part 63 (i.e.,
the General Provisions for NESHAP) require notification .
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60 days prior to the performance test date. Unless stated
otherwise, today's proposed rule follows the General ',
Provisions to part 63.
3. New Source Review/Prevention of Significant :
Deterioration Applicability :
The proposed level of gaseous organic HAP contrdl for
stand-alone semichemical combustion sources is based on the
* l
use of an RTO. The Agency expects that owners or operators
of sources that cannot meet the total gaseous organic HAP
emission limit (as THC) without add-on controls would
install an RTO to comply with the proposed NESHAP. However,
as demonstrated during a pilot study, RTO's can generate NOX
emissions during normal operation. The emission increases
of NOX may be of such magnitude to trigger the need for
preconstruction permits under the nonattainment new source
review (NSR) or prevention of significant deterioration
(PSD) program (hereinafter referred to as major NSR).
In a similar situation regarding the MACT standards for.
noncombustion sources in the pulp and paper industry ithat
are being promulgated today as part ,of the pulp and paper
industry cluster rule, industry and some States have '•
commented extensively that in developing the proposed rule,
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EPA did not take into.account the impacts that would be
incurred in triggering major NSR. Commenters indicated that
major NSR would: (1) cost the pulp and paper industry
significantly more for permitting and implementation of
•additional S02 or NOX controls than' predicted by EPA;
(2) impose a large permitting review burden on State air
quality offices; and (3) present difficulties for mills to
meet the proposed NESHAP compliance schedule of 3 years due
to. the time required to obtain a preconstruction permit.
Industry•commenters have stated that the pollution control
project (PCP) exemption allowed under the current PSD policy
provides inadequate relief from these potential impacts and
recommended'including specific language in the proposed rule
exempting MACT compliance projects from NSR/PSD.
In a July 1, 1994 guidance memorandum issued by the EPA
(available on the TTN; see "Pollution Control Projects and
New Source Review (NSR) Applicability" from John S. Seitz,
Director, OAQPS, to EPA Regional Air Division Directors),
the EPA provided guidance for permitting authorities on the
approvability of PCP exclusions for source categories other
than electric utilities. In the guidance, the EPA indicated
that add-on controls and fuel switches to less polluting
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fuels qualify for an exclusion from major NSR. To be
eligible to be excluded from otherwise applicable major NSR
requirements, a PGP must, on balance, be "environmentally
beneficial," and the permitting authority must ensure.that
the project will not cause or contribute to a violation of
the national ambient air quality standards (NAAQS) ori PSD
increment, or adversely affect visibility or other aiir
quality related values (AQRV) in a Class I area, and that
offsetting reductions are secured in the case of a.project
•which would result in a significant increase of a
t
nonattainment pollutant. The permitting authority can malte
these determinations outside of the major,NSR process. The
1994 guidance did not void or create an exclusion from any
applicable minor source preconstruction review requirements
in an approved State Implementation Plan (SIP) . Any minor
NSR permitting requirements in a SIP would continue to
apply, regardless of any exclusion from major NSR that might
be approved for a source under the PCP exclusion policy.
In the July 1, 1994 guidance memorandum, the EPA,
specifically identified the RTO as an example of an add-on
control that could be considered a PCP and an appropriate
candidate for a case-by-case exclusion from major NSR. For
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the purposes of today's proposed standards for chemical
recovery combustion sources at stand-alone semichemical pulp
mills, the EPA considers the application of the RTO to
reduce total gaseous organic HAP emissions to be a PCP
because the RTO is an add-on control device that would be
installed specifically to comply with MACT and will reduce
emissions of hazardous organic air pollutants. Furthermore,
EPA considers the installation of the RTO to be
environmentally beneficial because it would significantly
reduce emissions of VOC's and CO as well as the emissions of
the targeted pollutants (total gaseous organic HAP's).
However, EPA recognizes that incidental formation of NOX
will occur during operation of the RTO. Consistent with the
1994 guidance, the permitting authority should confirm that,
in each case, the resultant increase in NOX emissions would
not cause or contribute to a violation of a NAAQS, PSD
increment, or adversely affect an AQRV.
The EPA believes that the current guidance on pollution
control projects adequately provides for the exclusion from
major -NSR of air pollution control projects in the pulp and
paper industry resulting from today's proposed rule. Such
projects would be covered under minor source regulations in
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the applicable SIP, and permitting authorities would ;be
expected to provide adequate safeguards against NAAQS and
increment violations and adverse impacts on AQRV in Federal
Class I areas. Only in those areas where potential adverse
impacts cannot be resolved through the minor NSR programs or
other mechanisms would major NSR apply. ;
The EPA recognizes that, where there is a potential for
an adverse impact, some small percentage of mills located
near Class I PSD areas might be subject to major NSR, i.e.,
the permitting authority determines that the impact or
potential impact cannot be adequately addressed by its minor
NSR program or other SIP measures.' If this occurs, there is
a question whether MACT and NSR compliance can both be done
within the respective rule deadlines. Although too \
i
speculative to warrant disposition in this rule, EPA ;is
alert to this potential problem and will attempt to create
implementation flexibility oh a case-by-case basis should a
!
problem actually occur. ;
M. Solicitation of Comments ;
The EPA seeks full public participation in arriving at
its final decisions and encourages comments on all aspects
of this proposal from all interested parties. Full \
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supporting data and detailed analyses should be submitted
with comments to allow EPA to make maximum use of the
comments. All comments should be directed to the Air arid
Radiation Docket and Information Center, Docket No. A-94-67
(see ADDRESSES). Comments on this notice must be submitted
on or before the date specified in the "DATES" section.
Commentors wishing, to submit proprietary information
for consideration should clearly distinguish such
information from other comments and clearly label it
"Confidential Business Information" (CBI). Submissions
containing such proprietary information should be sent
directly to the Emission Standards Division CBI Office,
U. S. Environmental Protection Agency (MD-13), Research
Triangle Park, North Carolina 27711, with a copy of the
cover letter directed to Mr. Jeff Telander of the Minerals
and Inorganic Chemicals Group (see the "FOR FURTHER
INFORMATION CONTACT" section for the address). Confidential
business information should not be sent to the public
docket. Information covered by such a claim of
confidentiality will be disclosed by EPA only to the extent
allowed and by the procedures set forth in 40 CFR part 2.
If no claim of confidentiality accompanies the submission
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when it is received by EPA, it may be made available to the
public without further notice to the cotnmentor. :
V. Impacts of Proposed Standards ;
A. Number of Impacted Sources
An estimated 211 recovery furnaces, 227 SDT's, and
192 lime kilns currently operate at kraft and soda pulp
mills in the United States and would be affected by today's
proposed standards. The EPA estimates that 52 of the^
recovery furnaces, 56 of the SDT's, and 77 of the lime kilns
would be required to upgrade or replace add-on controls to
reduce emissions of PM HAP' s under the proposed standards..
(These estimates and the impacts estimates in the following
sections were determined based on control of PM or PM 'HAP
emissions without using the proposed bubble compliance
alternative.)
An estimated 21 sulfite combustion units and
14 semichemical combustion units currently operate in 'the
United States and would be affected by today's proposed
standards. Under the proposed standards, an estimated eight
sulfite combustion units would be required to upgrade ;or
replace add-on controls to reduce emissions of PM HAP''s; ana
estimated seven semichemical combustion units would be
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required to add controls to reduce emissions of total
gaseous organic HAP' s.
B. Environmental Impacts
Nationwide HAP emissions from combustion sources at
pulp mills are estimated to be 32,400 Mg/yr (35,700 tons/yr)
at the current level of control. The proposed standards are
estimated to reduce total HAP emissions by about 2,600 Mg/yr
(2,800 tons/yr). In addition to the HAP reductions, the
proposed standards would result in the reduction of criteria
air pollutants, such as PM and VOC. After implementation of
the proposed standards, PM emissions from combustion sources
at pulp mills are estimated to decrease by about 23,800
Mg/yr (26,200 tons/yr) from a baseline level of 64,400 Mg/yr
(71,000 tons/yr); VOC emissions from combustion sources at
stand-alone semichemical pulp mills are estimated to
decrease by about 32,600 Mg/yr (35,900 tons/yr) from a
baseline level of 36,600 Mg/yr (40,300 tons/yr); carbon
monoxide (CO) emissions from combustion sources at stand-
alone semichemical pulp mills are estimated to decrease by
about 57,700 Mg/yr (63,600 tons/yr) from a baseline level of
62,800 Mg/yr (69,200 tons/yr); and emissions of nitrogen
oxides (NOX) from combustion sources at stand-alone
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semichemical pulp mills are estimated to increase by about
476 Mg/yr (525 tons/yr) from a baseline level of 278 Mg/yr
(306 tons/yr). ; . - :
The quantity of PM collected will increase when
recovery furnace PM control devices are upgraded or replaced
to :comply with the proposed standards. However, no \
increases in solid waste disposal are expected becauste
existing mills have sufficient capacity within the chemical
recovery process to recycle the additional PM collected.
If owners or operators choose to replace wet scrubbers
with ESP's to comply with the proposed PM HAP standards for
lime kilns, the generation of wastewater will be reduced.
The significance of the reduction in wastewater will depend
on whether the scrubber discharge had previously- been;
recycled and reused. If wet scrubbers are replaced by ESP's
(and there was no prior recycle, or reuse of scrubber
discharge), EPA estimates that wastewater discharge will
decrease nationwide by about 36 billion liters per year
(L/yr) (9.5 billion gallons per year [gal/yr] ) following
implementation of the proposed standards.
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C. Energy Impacts
The overall- energy demand (i.e., electricity plus
natural gas) is expected to decrease by about 46.7 million
megajoules per year (MJ/yr) (44.3 billion British thermal
units per year [Btu/yr]) nationwide under the proposed
standards. Electricity requirements are expected to
decrease by about 17,200 megawatt-hours per year (MWh/yr)
under the proposed standard. This net decrease in
electricity requirements includes (1). an expected increase
of about 41,400 MWh/yr when PM control devices on kraft and
soda recovery furnaces and SDT's and sulfite combustion
units are upgraded or replaced, (2) an expected increase of
18,900 MWh/yr when total gaseous organic HAP control devices
are added to semichemical combustion units, and (3) an
expected decrease of about 77,500 MWh/yr if wet scrubbers
are replaced by ESP's to provide increased control of PM
emissions from lime kilns. Natural gas requirements are
expected to increase by about 0.4 million cubic meters per
year (m3/yr) (14 million cubic feet per year [ft3/yr] ) when
total gaseous organic HAP controls are added to semichemical
combustion units.
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D. Cost Impacts
i
The estimated capital costs of control for the proposed
standards are -$258 million. The capital costs of the
proposed standards include the costs to purchase and Install
both the control equipment and monitoring equipment. Most
(85 percent) of the capital costs can be attributed tp PM
controls for kraft and soda combustion sources (recovery
furnaces, lime kilns, and SDT's). The kraft and soda PM
control costs are estimated based on ESP upgrades for
recovery furnaces, replacement of existing wet scrubbers
with ESP's for lime kilns, arid replacement of existing wet
scrubbers with new wet scrubbers for SDT's. The proposed
bubble compliance alternative was not considered in :
estimating the capital PM control costs, and, therefore, the
L
capital costs may be overstated.
The incremental annual costs of the proposed standards
are $35.2 million/yr. The annualized costs account for the
year-to-year operating expenses associated with the cbntrol
equipment and the monitoring equipment, in addition to the
capital recovery expense associated with the equipment
purchases. Most (81 percent) of the annual costs can be
attributed to the PM controls for kraft and soda recovery
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furnaces and SDT's. The annual costs for lime kiln PM
controls are cost savings, based on the lower operating
costs for ESP's compared to wet scrubbers. The proposed
bubble compliance alternative was not considered in
estimating the annual PM control costs, and, therefore, the
annual costs may be overstated. The total average costs for
annual recordkeeping and reporting required by the proposed
standards are $6.8 million/yr over the first 3 years after
implementation of the standards.
E. Economic Impact
The economic impacts of today's proposed NESHAP (i.e.,
MACT II) and the NESHAP for noncombustion sources (i.e.,
MACT I and II) and effluent limitations guidelines being
promulgated today'are collectively discussed in section VIII
of the integrated preamble for "NESHAP for Source Category:
Pulp and Paper Production; Effluent Limitations Guidelines,
Pretreatment Standards, and New Source Performance
Standards: Pulp, Paper, and Paperboard'Category," hereafter
referred to as the integrated preamble.
F. Benefits Analysis
Implementation of the proposed regulation is expected
to reduce emissions of HAP's, PM, VOC, SO2, and CO, while it
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is expected to slightly increase emissions of NOX. The air
quality benefits expected to result from the above emission
reductions will be a decrease in adverse health effects
associated with inhalation of the above pollutants as,well
as improved welfare effects, such as improved visibility and
crop yields. The benefits analysis is able to quantify and
monetize the health and welfare benefits associated with
some of these emission reductions. Total monetized benefits
of the proposed regulatory alternative for VOC, PM, and SO2
emission reductions range from approximately $302 million to
$384 million. (Refer to the integrated preamble, and the
Economic Analysis Document for a detailed description.of the
methodology used to monetize the benefits.) \
\
Benefit categories that are monetized were compared to
annualized control costs of the regulatory alternatives to
determine net benefits. In general, the regulatory ;
. ' !
alternative with the greatest net benefits is optimal,from
an efficiency standpoint and will be the most beneficial to
society. Net benefits of the proposed regulatory :
alternative ($270 million to $352 million) are greater than
the net benefits of all other regulatory alternatives,
except those that combine the most stringent control options
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159
for kraft and soda mills. However, economic impact and
distributional issues must be considered in conjunction with
the cost-benefit analysis in the choice of proposed
regulatory alternative. • <
The control costs of the MACT II regulation increase
significantly between regulatory options one and four for
kraft and soda mills (see section IV.F of this notice).
Capital costs increase approximately 850 percent and
annualized costs 560 percent when comparing the costs of
option one versus four for kraft and soda mills. The
estimated increase in the price of unbleached kraft pulp
that will result from the MACT II rule differs greatly under
the different regulatory options as well. Specifically,
prices for unbleached kraft pulp are estimated to increase
from 1.4 percent with the least stringent option to
7.4 percent with the more stringent regulatory option for
kraft and soda mills.
Based on the economic impact analysis conducted, the
increased emission control costs associated with the most
stringent kraft and soda MACT II option are predicted to
result in one or more company bankruptcies in the pulp and
paper industry. Although the EPA can not determine with
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160 i
certainty the economic costs associated if one or more Icirge
firms experience bankruptcy, the EPA has reason to believe
that these impacts would likely be significant. Economic
impacts and distributional effects associated with :
bankruptcies may include issues involving changes in !the
ownership of the firm, loss in investment values for ;
existing investors in the firm, potentially higher financing
costs, possible mill closures, and probable job losses.
These factors were not directly considered in the cost-
benefit analysis conducted for the regulation.
While the cost-benefit analysis seems to indicate that
the net benefits of the most!stringent regulatory
; [
alternative exceed the net benefits of the proposed
j
alternative, the economic impact and distributional effects
associated with the most stringent option for kraft and soda
mills have not been considered directly in this analysis.
These economic impact and distributional issues lead to the
conclusion that the regulatory alternatives involving the
most stringent option for kraft and soda mills are le;ss than
optimal. ;
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161
VI. Administrative Requirements
A. Docket
The docket is an organized and complete file of all
information considered by EPA in developing this proposed
rule. The principal purposes of the docket are (1) to allow
interested parties to readily identify and locate documents
so that they can effectively participate in the rulemaking
process, and (2)'to serve as the record in case of judicial
review. (See section 307(d)(7) (A) of the CAA) .
B. Public Hearing
A public hearing will be held, if requested, to discuss
the proposed standards in accordance with section 307(d)(5)
of the Act. Persons wishing to make oral presentations on
the proposed standards should contact the EPA (see DATES for.
contact person and address). If a publice hearing is
requested and held, EPA will ask clarifying questions during
the oral presentation but will not respond to the
presentation of comments. To provide an opportunity for all
who wish to speak, oral presentations will be limited to
15 minutes each. Any member of the public may file a
written statement on or before [insert date 60 days from FR
publication]. Written statements should be addressed to the
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162
Air and Radiation.Docket and Information Center (see :
ADDRESSES) and refer to Docket No. A-94-67. Written 1
i
statements and supporting information will be considered
with equivalent -weight as any oral statement and supporting
information subsequently presented at a public hearing, if
held. A verbatim transcript;of the hearing and written
statements will be placed in I the docket and will be
l
available for public inspection and copying, or will be
mailed upon request, at the Air and Radiation Docket and
Information Center (see ADDRESSES). :
C. Executive Order 12866 !
'
Under Executive Order 12866 (58 FR 51736, October 4,
1993), the Agency must determine whether the regulatory
action is "significant" and, therefore, subject to review by
the Office of Management and Budget (OMB) and the ;
requirements of the Executive Order. The Executive Order
defines "significant regulatory action" as one that is
likely to result in a rule that may: ;
1. Have an annual effect on the economy of i
$100 million or more or adversely affect in a material way
the economy, a sector of the economy, productivity,
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163
competition, jobs, the environment, public health or safety,
or State, local, or Tribal governments or communities;
2. Create a serious inconsistency or otherwise
interfere with an action taken.or planned by another agency;
3. Materially alter the budgetary impact of
entitlements, grants, user fees, or loan programs or the
rights and obligations of recipients thereof; or
4. Raise novel legal or policy issues arising out of
legal mandates, the President's priorities, or the
principles set forth in the Executive Order.
Pursuant 'to the terms of Executive Order 12866, OMB has
notified EPA that this action is a "significant regulatory
action" within the meaning of the Executive Order. For that
reason, this action was submitted to OMB for review. The
regulatory impact assessment (RIA) is detailed in the
Economic Analysis Document (docket No. II-A-32). Changes
made in response to' OMB suggestions or recommendations will
be documented in the public record.
D. Enhancing the Interdepartmental Partnership Under
Executive Order 12875
In compliance with Executive Order 12875, the Agency
has involved State regulatory experts in the development of
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164 • '
this proposed rule. No Tribal governments are believed to
be affected by this proposed rule. State and local ,
governments are not directly impacted by the rule, i.e.,
i
they are not required to purchase control systems to meet
the requirements of the rule. However, they will be
required to implement .the rule; e.g., incorporate the rule
into permits and enforce the rule. They will collect permit
fees that will be used'to offset the resources burden:of
implementing the rule. Comments have been solicited from
States and have been carefully considered in the rule,
development process. In addition, all States are encouraged
to comment on this proposed rule during the public comment
period, and the EPA intends to fully consider these comments
in the development of the final rule.
E. Unfunded Mandates Reform Act [
Title II of the Unfunded Mandates Reform Act of 1995
(UMRA), P.L. 104-4, establishes requirements for Federal
agencies to assess the effects of their regulatory actions
on State, local, and tribal governments and-the private
sector. Under section 202 of the UMRA, EPA generally must
prepare a written statement, including a cost-benefit
analysis, for proposed and final rules with "Federal
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165
mandates" that may result in expenditures to.- State, local,
and tribal governments, in the aggregate, or to the private
sector, of $100 million or more in any one year. Before
promulgating an EPA rule for which a written statement is
needed, section 205 of the UMRA generally requires EPA to
identify and consider a reasonable number- of regulatory
alternatives and adopt the least costly, most cost-effective
or least burdensome alternative that achieves the objectives
of the rule. The provisions of section 205 do not apply
when they are inconsistent with applicable .law. Moreover,
section 205 allows EPA to adopt an alternative other than
the least costly, most cost-effective or least burdensome
alternative if the Administrator publishes with the final
rule an explanation why that alternative was not adopted.
Before EPA establishes any regulatory requirements that may
significantly or uniquely affect small governments,
including tribal governments, it must have developed under
section 203 of the UMRA a small government agency plan. The
plan must provide for notifying.potentially affected small
\
governments, enabling officials of affected small
governments to have meaningful and timely input in the
development of EPA regulatory proposals with significant
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166 :
Federal intergovernmental mandates, and informing,
educating, and advising small governments on compliance with•
the regulatory requirements.
The EPA has determined that this rule contains a
F
Federal mandate that may result in expenditures of
$100 million or more for State, local, and Tribal
governments, in the aggregate, or the private sector in any
one year. Accordingly, EPA has'prepared under section 202
of the UMRA a written statement which is summarized below.
i
1. Statutory Authority ' j
As discussed in section I of this preamble, the
statutory authority for this rulemaking is section 112 of
the CAA. Title III of the CAA Amendments was enacted to
reduce the amount of nationwide air toxic emissions.
Section 112(b) lists the 189 chemicals, compounds, or groups
of'chemicals deemed by Congress to be HAP's. These toxic
air pollutants are to be regulated by NESHAP. Hazardous air
pollutant emissions from the pulp and paper production
source category are being regulated under section 112(d) of
the CAA. The NESHAP requires existing and new major sources
to control emissions of HAP's using the maximum achievable
control technology (MACT). |
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167
The pulp and paper production source category includes
all mills that produce pulp and/or paper. The NESHAP for
the source category are being developed in phases. This
proposed NESHAP, referred to as MACT II, regulates chemical
recovery combustion sources at kraft, soda, sulfite, and
stand-alone semichemical pulp mills. The final NESHAP for
noncombustion sources regulates noncombustion processes at
mills that (1) chemically pulp wood fiber (using kraft,
sulfite, soda, and semi-chemical methods) (MACT I), and (2)
mechanically pulp wood fiber (e.g., groundwood,
thermomechanical, pressurized), pulp secondary fibers
(deinked and nondeinked), and pulp nonwood (MACT III).
Compliance with section 205 (a) -. Regarding the EPA's
compliance with section 205(a), the EPA did identify and
consider a reasonable number•of alternatives; a summary of
these alternatives is provided in section IV.F of this
preamble. Additional information,on the costs and
environmental impacts of the regulatory alternatives is
presented in the Nationwide Costs, Environmental Impacts,
and Cost-Effectiveness of Regulatory Alternatives for Kraft,
Soda, Sulfite, and Semichemical Combustion Sources Memo
(docket No. II-B-63).
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,168 ;
The chosen alternative represents the MACT floor.for
chemical recovery combustion sources at kraft, soda a|nd :
sulfite pulp mills and is the least costly and least ' ;
burdensome alternative for those sources. The chosen * •
i
alternative also includes an option more stringent than the
MACT floor for chemical recovery combustion sources at ;
semichemical pulp mills. However, the EPA considers the
i
cost-effectiveness of the more stringent option for ;
semichemical chemical recovery combustion sources (less than
$2,800/Mg HAP's, based on conservative cost estimates)
acceptable, especially when measured against the |
environmental benefits of reducing 'emissions of both HAP's ^^
and non-HAP's. Therefore, the EPA concludes that the' chosen . ;
alternative is the least costly and least burdensome
alternative that achieves the objectives of section li2, as
called for in section 205(a) .
2. Social Costs and Benefits i
The regulatory impact analysis prepared for the
proposed NESHAP for MACT I, including the Agency's :
assessment of costs and environmental benefits, is detailed
in the "Regulatory Impact Assessment of Proposed Effluent
Guidelines and NESHAP for the Pulp, Paper, and Paperboard
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169
Industry," (EPA 821-R93-020). The regulatory impact
assessment document has been updated for the final rule for
MACT I and III and the proposed rule for MACT II and is
referred to as the Economic Analysis Document (docket No.
II-A-32). Social costs and benefits also are discussed in
section V of this preamble.
3. Future and Disproportionate Costs
The Unfunded Mandates Act requires that EPA estimate,
where accurate estimation is reasonably feasible, .future
compliance costs imposed by the rule and any
disproportionate budgetary effects. The EPA's estimates of
the future compliance costs of this rule are discussed in
section V.D of this preamble.
The EPA does not believe that there will be any
disproportionate budgetary -effects of the rule on any
particular areas of the country, particular governments or
types of communities (e.g., urban, rural), or particular
industry segments.
4. Effects on the National Economy
The Unfunded Mandates Act requires that EPA estimate
the effect of this rule on the national economy. To the
extent feasible, EPA must estimate the effect on
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170
productivity, economic growth, full employment, creation of
i ;
productive jobs, and international competitiveness of: the
I
U.S. goods and services, if and to the extent that this EPA
in its sole discretion determines that accurate estimates
are reasonably feasible and that such effect is relevant and
material.
s
Estimates of the impact of this rule on the national
economy are described in section VIII of the integrated
preamble to the final rule for MACT I and III and the:
I .
effluent guidelines that are being promulgated today. The
nationwide economic impact of .the rule is based on the
Economic Analysis Document (docket No. II-A-32). i
5. Consultation with Government Officials . I
The Unfunded Mandates Act requires that EPA describe
the extent of the agency's prior consultation with affected
State, local, and tribal officials, summarize the officials'
comments or concerns, and summarize EPA's response to those
comments or concerns. In addition, section 203 of the Act
i - !
requires that EPA develop a plan for informing and advising
small governments that may be. significantly or uniquely
impacted by a proposal. Although this rule does not affect
any State, local, or Tribal governments, EPA has consulted
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171
with State and local air pollution control officials. The
Agency also has held numerous meetings on these proposed
integrated rules with many of the stakeholders from the pulp
and paper industry, including the American Forest and Paper
Association (AF&PA), the National Council of the Paper
Industry; for Air and Stream Improvement (NCASI), numerous
individual companies, environmental groups, consultants and
vendors, labor unions, and other interested parties. The
EPA has added materials to the Air and Water docket to
document these meetings.
F. Regulatory Flexibility
The Regulatory Flexibility Act (RFA)(5 U.S.C. 601 et
seq. , Pub.. L. 96-354), amended by the Small Business
Regulatory Enforcement Fairness Act of 1996 (SBREFA),
requires the Agency to examine the potential economic impact
of regulatory action on small entities. ' The Agency has
recently established guidelines to help analysts comply with
RFA requirements, and to determine if a substantial number
of small businesses are significantly impacted. The Agency
has estimated the economic impact of the integrated
regulatory alternative on small companies involved in pulp,
paper, and paperboard manufacturing, and these impacts are
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172 • ;
discussed in the integrated preamble to the final rule for
MACT I and III and the effluent limitations guidelines being
promulgated today and in the Economic Analysis Document
(docket No. II-A-32) . As explained there, the CAA rule does
not have a significant economic impact on a substantial
number of small'entities, within the meaning of-
section 605(b) of the Regulatory Flexibility Act. Inimaking
this finding, the Agency explicitly considered the potential
impacts of this proposal in combination with both the:final
CAA rules, and also the final CWA rule. The EPA adopts the
same analysis here, and, thus., certifies that this proposed
rule does not have a significant impact on a substantial
number of small entities. !
G. Paperwork Reduction Act
The information collection requirements in this -
proposed rule have been submitted for approval to OMB:under
the Paperwork Reduction Act, 44 U.S.C. 3501 et 'seq. An
•
Information Collection Request (ICR) document has been
i
prepared by EPA (ICR No.1805.01), and a copy may be obtained
from Sandy Farmer, OPPE Regulatory Information Division
(2136); U. S. Environmental Protection Agency (2136); 401 M
Street SW.; Washington, D.C. 20460, or by calling ;
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Federal departments and agencies. Pursuant to
section 112(f), this regulation will be reviewed 8 years
from the date of promulgation. This review will include an
assessment of such factors as evaluation of the residual
health risks, any overlap with other programs, the existence
of alternative methods, enforceability, improvements in
emission control technology and health data, and reporting
and recordkeeping requirements.
List of Subject in 40 CFR Part 63
Air pollution control, Hazardous air pollutants, Pulp
and paper mills, Reporting and recordkeeping requirements.
Date, Carol M. Browner, Administrator
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175 ;
It is proposed that part 63, chapter I, title 40.of the
Code of Federal Regulations be amended as follows: i
PART 63 - FAMENDED! ! i
1. The authority citation for part 63 continues.to
read as follows:
Authority: 42 U.S.C. 7401 et seq.
2. By adding a new subpart MM, consisting of.
§§ 63.860-63.868, to read as follows:
Subpart MM -- National Emission Standards for Hazardous Air
Pollutants; Proposed Standards for Hazardous Air Pollutants
from Chemical Recovery Combustion Sources at Kraft, Soda,
Sulfite, and Stand-Alone Semichemical Pulp Mills.
1
Sec.
63.860 Applicability and designation of affected source.
63.861 Definitions. \
63.862 Standards.
63.863 Compliance dates.
63.864 Monitoring requirements. ;
63.865 Performance test requirements and test methods.
63.866 Recordkeeping requirements.
63.867 Reporting requirements.
63.868 Delegation of authority. ;
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§63.860 Applicability and designation of affected source.
(a) This subpart applies to the NDCE.recovery
furnaces, DCE recovery furnace systems, smelt dissolving
tanks, and lime kilns at kraft and soda pulp mills; the
sulfite combustion units at sulfite pulp mills; and the
semichemical combustion units at stand-alone semichemical
pulp mills.
(b) Affected sources. The affected .sources to which
•
the provisions of this subpart apply are:
(1) Each NDCE recovery furnace and associated smelt
dissolving tank(s) located at a kraft or soda pulp mill.
(2) Each DCE recovery furnace system and associated
smelt dissolving tank(s) located at a kraft or soda pulp
mill.
(3) Each lime kiln located at a kraft or soda pulp
mill.
4) Each sulfite combustion unit located at a sulfite
pulp mill.
(5) Each semichemical combustion unit located at a
stand-alone semichemical pulp mill.
(c) The owner or operator of an affected source
subject to the provisions of this subpart must also comply
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177
with the requirements of subpart A of this part, according
to the applicability of subpart A to such affected sources,
as identified in. Table 1.
§ 63.861 Definitions. •
; All terms used in this subpart are defined in the Act,
in subpart A of this part, or in this section. For the
i
purposes of this subpart, if the same term is defined in
subpart A or any other subpart of this part and in this
i
section, it shall have the meaning given in this section.
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TABLE 1. GENERAL PROVISIONS APPLICABILITY TO SUBPART MM
General
provisions
reference
63.1(a)(l)
63.1(a)(2)-
(14)
63.1(b)(l)
63.1(b)(2)
63.1(b)(3)
63.1(c)(l)
63.1(c)(2)
63.1(c)(3)
63.1(c)(4)
63.1(c)(5)
63.1(d)
63.1(e)
Summary of requirements
General applicability of the General
Provisions.
Initial applicability determination.
Title V operating permit - see part 70.
Record of the applicability
determination.
Applicability of subpart A after a
relevant standard has been set.
Title V permit requirement.
[Reserved]
Requirements for existing source that
obtains an extension of compliance.
Notification requirements for an area
source that increases HAP emissions to
major source levels.
[Reserved]
Applicability of permit program before
a relevant standard has been set.
Applies to
subpart
MM
Yes
Yes
No
Yes
No
Yes
Yes
NA
Yes
Yes
NA
Yes
Comments
Additional terms defined in
§ 63.861; when overlap
between subparts A and
MM of this part,
subpart MM takes
precedence.
Subpart MM specifies the
applicability in § 63.860
All major affected sources
are required to obtain a title
V permit.
All affected sources are
subject to subpart MM
according to the
applicability definition of
subpart MM.
Subpart MM clarifies the
applicability of each
paragraph of subpart A to
sources subject to
subpart MM.
All major affected sources
are required to obtain a title
V permit. There are no
area sources in the pulp and
paper mill source category.
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General
provisions
reference
63.2
63.3
63.4
63.5(a)
63.5(b)(l)
63.5(b)(2)
63.5(b)(3)
63.5(b)(4)
63.5(b)(5)
63.5(b)(6)
63.5(c)
63.5(d)
63 .5(e)
63.5(f)
63.6(a)(l)
63.6(a)(2)
63.6(b)
63.6(c)
Summary of requirements
Definitions.
1
Units and abbreviations.
Prohibited activities and circumvention.
Construction and reconstruction -
applicability.
Upon construction, relevant standards
for new sources.
[Reserved]
New construction/reconstruction.
Construction/reconstruction
notification.
Construction/reconstruction
compliance.
Equipment addition or process change.
[Reserved]
Application for approval of
construction/reconstruction.
Construction/reconstruction approval.
Construction/reconstruction approval
based on prior State preconstruction
review.
Compliance with standards and
maintenance requirements -
applicability.
Requirements for area source that
increases emissions to become major.
Compliance dates for new and
reconstructed sources.
Compliance dates for existing sources.
Applies to
subpart
MM
Yes
Yes
Yes
Yes
Yes
NA
Yes
Yes
Yes
Yes
NA
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Comments
Additional terms defined in
§ 63.861; when overlap
between subparts! A and
MM of this part occurs,
subpart MM takes
precedence.
;
'
!
t
i
Subpart MM specifically
stipulates the compliance
schedule for existing
sources.
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General
provisions
reference
63.6(d)
63.6(e)
63.6(f)
63.6(g)
63.6(h)
63.6(i)
63.6(j)
63.7(a)(l)
63.7(a)(2)
63.7(a)(3)
63.7(b)(l)
63.7(b)(2)
63.7(c)
63.7(d)
63.7(e)
63.7(f)
63.7(g)
63.7(h)
Summary of requirements
[Reserved]
Operation and maintenance
requirements.
Compliance with nonopacity emission
standards.
Compliance with alternative nonopaciry
emission standards.
Compliance with opacity and visible
emission (V.E.) standards
Extension of compliance with emission
standards.
Exemption from compliance with
emission standards.
Performance testing requirements -
applicability
Performance test dates.
Performance test requests by
Administrator under section 1 14.
Notification of performance test.
Notification of delay hi conducting a
scheduled performance test.
Quality assurance program.
Performance testing facilities.
Conduct of performance tests.
Use of an alternative test method.
Data analysis, recordkeeping, and
reporting.
Waiver of performance tests.
Applies to
subpart
MM
NA
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Comments
Subpart MM does not
contain any opacity or V.E.
standards; however,
§ 63.864 specifies opacity
monitoring requirements.
§ 63.864(a)(6) specifies the
only exemption from
performance testing allowed
under subpart MM.
-
§ 63.864(a)(6) specifies the
only exemption from
performance testing allowed
under subpart MM.
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181
General
provisions
reference
63.8(a)
63.8(b)
63.8(c)
63.8(d)
63.8(e)(l)
63.8(e)(2)
63.8(e)(3)
63.8(e)(4)
63.8(e)(5)
63.8(f)
63.8(g)
63.9(a)
63,9(b)
63.9(c)
63.9(d)
63.9(e)
63.9(f)
63.9(g)(l)
63.9(g)(2)
Summary of requirements
Monitoring requirements -
applicability.
Conduct of monitoring.
Operation" and maintenance of CMS.
Quality control program.
Performance evaluation of CMS.
Notification of performance evaluation.
Submission of site-specific
performance evaluation test plan.
Conduct of performance evaluation and
performance evaluation dates.
Reporting performance evaluation
results.
Use of an alternative monitoring
method. ;
Reduction of monitoring data.
Notification requirements -
applicability and general information.
Initial notifications.
Request for extension of compliance.
Notification that source subject to
special compliance requirements.
Notification of performance test.
Notification of opacity and V.E.
observations.
Additional notification requirements for
sources with CMS.
Notification of compliance with opacity
emission standard.
Applies to
subpart
MM
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Comments
See § 63.864 ,
i
j -
Subpart MM does not
contain any opacity or V.E
standards; however,
§ 63.864 specifies opacity
monitoring requirements.
Subpart MM does not
contain any opacity or V.E.
emission standards;
however, § 63.864 specifies
opacity monitoring
requirements.
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182
General
provisions
reference
63.9(g)(3)
63.9(h)
63.9(i)
63.90)
63.10(a)
63.10(b)(l)
63.10(b)(2)
63.10(b)(3)
63.10(c)
63.10(d)(l)
63.10(d)(2)
63.10(d)(3)
63.10(d)(4)
63.10(d)(5)
63.10(e)
63.10(f)
63.11
Summary of requirements
Notification that criterion to continue
use of alternative to relative accuracy
testing has been exceeded.
Notification of compliance status.
Adjustment to time periods or postmark
deadlines for submittal and review of
required communications.
Change in information already
provided.
Recordkeeping requirements -
applicability and general information.
Records retention.
Information and documentation to
support notifications and demonstrate
compliance.
Records retention for sources not
subject to relevant standard.
Additional recordkeeping requirements
for sources with CMS.
General reporting requirements.
Reporting results of performance tests.
Reporting results of opacity or V.E.
observations.
Progress reports.
Periodic and immediate startup,
shutdown, and malfunction reports.
Additional reporting requirements for
sources with CMS.
Waiver of recordkeeping and reporting
requirements.
Control device requirements for flares.
Applies to
subpart
MM
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
No '
Comments
See § 63.866
Applicability requirements
are given in § 63.860.
Subpart MM does not
include any opacity or
visible emission standards;
however, § 63.864
specifies opacity monitoring
requirements.
The use of flares to meet
the standards in
subpart MM is not
anticipated.
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183
General
provisions
reference
63.12
63.13
63.14
63.15
Summary of requirements
State authority and delegations.
Addresses of State air pollution control
agencies and EPA Regional Offices.
Incorporations by reference.
Availability of information and
confidentiality.
Applies to
subpart
MM
Yes
Yes
Yes
Yes
Comments
!
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184
Black liquor means spent cooking liquor that has been
separated from the pulp produced by the kraft, soda, or
semichemical pulping process.
Black liquor oxidation (BLO) system means the vessels
used to oxidize the black liquor, with air or oxygen, and
the associated storage tank(s).
Black liquor solids (BLS) means the dry weight of the
solids in the black liquor that enters the recovery furnace
or semichemical combustion unit.
Black liquor solids firing rate means the rate at which
black liquor solids are fed to the recovery furnace or the
semichemical combustion unit.
Chemical recovery combustion source means any source in
the chemical recovery area of a kraft, soda, sulfite or
stand-alone semichemical pulp mill that is an NDCE recovery
furnace, a DCE recovery furnace system, a smelt dissolving
tank (SDT), a lime kiln, a sulfite combustion unit, or a
semichemical combustion unit.
Direct contact evaporator (DCE) recovery furnace,means
a kraft or soda recovery furnace equipped with a direct
contact evaporator that concentrates strong black liquor by
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185
direct contact between the hot recovery furnace exhaust
'
gases and the strong black liquor.
Direct contact evaporator (DCE) recovery furnace system
means a direct contact evaporator recovery furnace arid any
black liquor oxidation system, if present, at the pulp mill.
Dry electrostatic precipitator (ESP) system means an
electrostatic precipitator with a dry bottom (i.e., ho black
liquor, water, or other fluid is used in the ESP bottom) and
a dry particulate matter (PM) return system (i.e.,. no black
liquor, water, or other fluid is used to transport the
! (
collected PM to the mix tank). ;
Kraft pulp mill means any 'stationary source that
produces pulp from wood by cooking (digesting) wood chips in
a solution of sodium hydroxide and sodium sulfide. The
recovery process used to regenerate cooking chemicals, is
i
also considered part of the kraft pulp mill.
Kraft recovery furnace means a recovery furnace 'that, is
used to burn black liquor produced by the kraft pulping
process, as well as any recovery furnace' that burns black
liquor produced from both the kraft and semichemical pulping,
processes, and includes the direct contact evaporator, if
applicable.
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186
Lime production :rate means the rate at which dry lime,
measured as calcium oxide (CaO), is produced in the lime
kiln.
Lime kiln means the combustion unit (e.g., rotary lime
kiln or fluidized-bed calciner) used at a kraft or soda pulp
mill to calcine lime mud, which consists primarily of
calcium carbonate, into quicklime, which is CaO.
Method detection limit means the minimum concentration
of an analyte that can be determined with 99 percent
confidence that the true value is greater than zero.
Modification means, for the purposes of
§63.862 (a) (1) (ii) ,(E) (1) , any physical change (excluding any
routine part replacement or maintenance) or operational
change (excluding any operational change that occurs during
a start-up, shutdown, or malfunction), that is made to the
air pollution control device that could result in an
increase in PM emissions.
Nondetect data means, for the purposes of this subpart,
any value that is below the method detection limit.
Nondirect contact evaporator (NDCE) recovery furnace
means a kraft or soda recovery furnace that burns black
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187
liquor that has been concentrated by indirect contact with
steam. I ;
Particulate matter (PM) means total particulate matter
as measured by EPA Method 5,,EPA Method 17 (see
§ 63.865(b) (1)), or EPA Method 29. |
I
PM hazardous air pollutant (HAP) means the sum of all
emissions of antimony, arsenic, beryllium, cadmium,
chromium, cobalt, lead, manganese, mercury, nickel, and
selenium as measured by EPA Method 29 and with treatment of
nondetect data as specified in § 63.865(b)(2).
Recovery furnace means an enclosed combustion device
where concentrated black liquor produced by the kraft or
soda pulping process is burned to recover pulping chemicals
and produce steam.
Regenerative thermal oxidizer (RTO) means a thermal
i '
oxidizer that transfers heat from the exhaust gas stream to
the inlet gas stream by passing the exhaust stream through a
bed of ceramic stoneware or other heat-absorbing medium
before releasing it to the atmosphere, then reversing the
gas flow so the inlet gas stream passes through the heated
bed, raising the temperature of the inlet stream close to or
at its ignition temperature.
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188
Semi-chemical combustion unit means any equipment used
to combust or pyrolyze black liquor at stand-alone
semichemical pulp mills for the purpose of chemical
recovery.
Smelt dissolving,tank (SDT) means a vessel used for
dissolving the smelt collected from a kraft or soda recovery
furnace. .
Similar process units means all DCE and NDCE recovery
furnaces, all smelt dissolving tanks, or all lime kilns at a
kraft or soda pulp mill.
Soda pulp mill means any stationary source that
produces pulp from wood by cooking (digesting) wood chips in.
a sodium hydroxide solution. The recovery process used to
regenerate cooking chemicals is also considered part of the
soda pulp mill.
Soda recovery furnace means a recovery furnace used to
burn black liquor produced by the soda pulping process, and
includes the direct contact evaporator, if applicable.
Stand-alone semichemical pulp mill means any stationary
source that produces pulp from wood by partially digesting
wood chips in a chemical solution followed by mechanical
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1189
defibrating (grinding) and has an onsite chemical recovery
process that is not integrated with a kraft pulp mill1.
Sulfite pulp mill means any stationary source that
'
produces pulp from wood by cooking (digesting) wood chips in
a solution of sulfurous acid and bisulfite ions. The
!
recovery process used to regenerate cooking chemicals; is
also considered part of the sulfite pulp mill.
Sulfite combustion unit means a combustion device, such
as a recovery furnace or fluidized-bed reactor, where spent
liquor from the sulfite pulping process (i.e., red liquor)
is burned to recover pulping i chemicals .
Total hydrocarbons (THC) means the sum of organic
compounds measured as carbon Busing EPA Method 25A. :
§ 63.862 Standards. •
•
. (a) Standards for PM HAP: existing sources.
(1) Each owner or operator of an existing kraft. or
soda pulp mill shall comply with the requirements of either
paragraph (a)(1)(i) or paragraph (a)(1)(ii) of this section.
(i) Each owner or operator of a kraft or soda pulp
mill shall comply with either the PM or PM HAP emission
limits in paragraphs (a) (1) (i) (A) through (C) of this
section.
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190
(A) The owner or Operator of each existing kraft or
soda recovery furnace shall ensure that:
(1) The concentration of PM in the exhaust gases
discharged to the atmosphere is less than or equal to
0.10 g/dscm (0.044 gr/dscf) corrected to 8 percent oxygen;
or
(2) The PM HAP emissions discharged to the atmosphere
are less than or equal to l.OOE-03 kg/Mg (2.01E-03 Ib/ton)
of black liquor solids fired.
(B) ,The owner or operator of each existing kraft or
soda smelt dissolving tank shall ensure that:
(1) • The concentration of PM in the exhaust gases
discharged to the atmosphere is less than or equal to
0.10 kg/Mg (0.20 Ib/ton) of black liquor solids fired; or
(2) The PM HAP emissions discharged to the atmosphere
are less than or equal to 6.20E-05 kg/Mg (1.24E-04 Ib/ton)
of black liquor solids fired.
(C) The owner or operator of each existing kraft or
soda lime kiln shall ensure that:
(1) The concentration of PM in the exhaust gases
discharged to the atmosphere is less than or equal to
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191 i
0.15 g/dscm (0.067 gr/dscf) corrected to 10 percent oxygen;
i • i
or j-
(2) The PM HAP emission's discharged to the atmosphere
are less than or equal to 6.3'3E-03 kg/Mg (1.27E-02 Ib/ton)
of CaO produced. ;
(ii) As an alternative to meeting the requirements of
i
§ 63.862 (a) (1) (i) , each owner; or operator of a kraft 6r soda
pulp mill may establish PM or. PM HAP emission limits for
each existing kraft or soda recovery furnace, smelt •
dissolving tank, and lime kiln that operates 6,300 hours per
year or more by: |
(A) Establishing an overall PM emission limit for all
affected existing sources at the kraft or soda pulp mill
using the methods in § 63.865(a)(1)(i); or ' ;
(B) Establishing an overall PM HAP emission limit for
all affected existing sources at the kraft or soda pulp mill
using the methods in § 63.865(a)(1)(ii).
(C) The emission limits for each kraft recovery',
furnace, smelt dissolving tank, and lime kiln that are used
to establish the overall PM limit in paragraph (a)(2)(ii)(A)
of this section shall not be less stringent than the
emission limitations required! by § 60.282 of part 60 for any
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192
kraft recovery furnace, smelt dissolving tank, or lime kiln
that is subject to the requirements of § 60.282.
(D) Each owner or operator of an existing kraft or
soda recovery furnace, smelt dissolving tank, or lime kiln
shall ensure that the PM or PM HAP emissions discharged to
the atmosphere from each of these sources are less than or
equal to the applicable PM or PM HAP limits, established
using the methods in § 63.865(a)(1)(i) or (ii) , that are
used to establish the overall PM or PM HAP limit in
paragraphs (a)(2)(ii)(A) or (B) of this section.
(E) Each owner or operator of an existing kraft or
soda recovery furnace, smelt dissolving tank or lime kiln
must reestablish the emission limits determined in
paragraphs (a) (1) (ii) (A) or (B) of this section .if either of
the following actions are taken:
(1) The air pollution control system for any existing
kraft or soda recovery furnace, smelt dissolving tank, or
lime kiln for which an emission limit was established in
paragraphs (a)(1)(ii)(A) or (B) is modified (as defined in
§63.861) or replaced; or
(2) Any kraft or soda recovery furnace, smelt
dissolving tank, or lime kiln for which an emission limit
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'193
was established in paragraphs (a) (1) (ii) (A) or (B) 'is. shut
down for more than 60 consecutive days.
(iii) Each owner or operator of an existing kraft or
i
soda recovery furnace, smelt:dissolving tank, or lime: kiln
that operates less than 6,300 hours per year shall comply
with the applicable PM or PM HAP emission limit for that
source provided in paragraph'(a)(1)(i) of this section.
(2) The owner or operator of each existing sulfite
combustion unit shall ensurethat the concentration of PM in
the exhaust gases discharged to the atmosphere is less than
or equal to 0.092 g/dscm (0.040 gr/dscf) corrected to
;
8 percent oxygen. ', :
(b) Standards_fQr_J?M HAP: new sources.
(1) The owner or operator of any new kraft or soda
recovery furnace shall ensure that the concentration of PM
in the exhaust gases discharged to the atmosphere is less
than or equal to 0.034 g/dscm (0.015 gr/dscf) corrected to
I
8 percent oxygen. , •
(2) The owner or operator of any new kraft or soda
smelt dissolving tank shall ensure that the concentration of
PM in the exhaust gases discharged to the atmosphere is less
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194
than or equal to 0.06 kg/Mg (0.12 Ib/ton) of black liquor
solids fired.
(3) The owner or operator of any new kraft or soda
lime kiln shall ensure that the concentration of PM in the
exhaust gases discharged to the atmosphere is less than or
equal to 0.023 g/dscm (0.010 gr/dscf) corrected to
10 percent oxygen.
(4) The owner or operator of any new sulfite
combustion unit shall ensure that the concentration of PM in
the exhaust gases discharged to the atmosphere is less than
or equal to 0.046 g/dscm (0.020 gr/dscf) corrected to
8 percent oxygen.
(c) Standards for total gaseous organic HAP.
(1) The owner or operator of any new recovery furnace
at a kraft or soda pulp mill shall ensure that the
concentration of total gaseous organic HAP, as measured by
methanol, discharged to the atmosphere is no greater than
0.012 kg/Mg (0.025 Ib/ton) of black liquor solids fired.
(2) The owner or operator of each existing or new
semichemical combustion unit shall ensure that:
(i) The concentration of total gaseous organic HAP, as
measured by total hydrocarbons reported as carbon,
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195
discharged to the atmosphere is less than or equal to,
1.49 kg/Mg (2.97 Ib/ton) of black liquor solids fired;; or
(ii) The total gaseous organic HAP emissions, as
measured by total hydrocarbons reported as carbon, are
reduced by at least 90 percent prior to discharge of the
[
gases to the atmosphere.
§ 63.863 Compliance dates.
(a) The owner or operator of an existing affected
source shall comply with the ^requirements in this subpart no
later than 3 years after the effective date.
(b) The owner or operator of a new affected source
that has an initial startup date after the effective date of
these standards shall comply with the requirements in; this
subpart immediately upon startup of the affected source,
exdept as specified in § 63.6(b) of subpart A of this part.
i
§ 63.864 Monitoring requirements. '
(a) General.
(1) The owner or operator of each affected kraft or
soda recovery furnace or lime kiln equipped with an ESP
shall install, calibrate, maintain, and operate a continuous
opacity monitoring system that can be used to determine
opacity at least once every successive 10-second period and
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196
calculate and record each successive 6-minute average
opacity using the procedures in §§ 63.6(h) and 63.8 of
subpart A of this part.
(2) The owner or operator of each affected kraft or
soda lime kiln, sulfite recovery furnace,•or kraft or soda
smelt dissolving tank equipped with a wet scrubber shall
install, calibrate, maintain, and operate a continuous
monitoring system that can be used to determine and record
the pressure drop across the scrubber and the scrubbing
liquid flowrate at least once every successive 15-minute
period using the procedures in § 63.8(c) as well as the
following:
(i) The monitoring device used for the continuous
measurement of the pressure drop of the gas stream across
the scrubber shall be certified by the manufacturer to be
accurate to within a gage pressure of ±500 pascals
(±2 inches of water gage pressure); and
(ii) The monitoring device used for continuous
measurement of the scrubbing liquid flowrate shall be
certified by the manufacturer to be accurate within
±5 percent of the design scrubbing liquid flowrate.
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197
(3) The owner or operator of each affected
semichemical combustion unit equipped with an RTO shall
install, calibrate, maintain, and operate a continuous
monitoring system that can be used to determine and record
the operating temperature of the RTO at least once every
i
successive 15-minute period Busing the procedures in !
§ 63.8(c). The monitor shall compute and record the'
operating temperature at the point of incineration of
effluent gases that are emitted using a temperature monitor
accurate to within ±1 percerit of the temperature being
measured. , \
(4) The owner or operator of each affected source that
uses a control device listed in paragraphs (a)(1) through
(a) (3) of this section may monitor alternative control
device operating parameters subject to prior written
I "
approval by the Administrator.
(5) The owner or operator of each affected source that
uses an air pollution control system other than those listed
in paragraphs (a) (1) through (a) (3) of this section shall
monitor the parameters as approved by the Administrator
using the methods and procedures in § 63.865(f).
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198
(6) The owner or operator of each affected source
complying with the total gaseous organic HAP emission
limitations of § 63.862(c)(1) through the use of an NDCE
recovery'furnace equipped with a dry ESP system is not
required to conduct any performance testing or any
continuous monitoring to demonstrate compliance with the
total gaseous organic HAP emission limitation.
(fc>) initial compliance determination.
(1) The owner or operator of each affected source
subject to the requirements of this subpart is required to
conduct•an initial performance test using the test methods
and procedures listed in § 63.7 of subpart A of this part
and § 63.865, except as provided in paragraph (b)(3) of this
section.
(2) Determination of operating ranges.
(i) During the initial performance test required in
paragraph (b)(1) of this section, the owner or operator of
any affected source shall establish operating ranges for the
monitoring parameters in paragraphs (a)(2) through (a)(5) of
this section, as appropriate; or
(ii) The owner or operator may base operating ranges
on values recorded during previous performance tests or
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199
conduct additional performance tests for the specific,
purpose of establishing operating ranges, provided that test
data used to establish the operating ranges are or have been
obtained using the test methods required in this subpart.
The owner or operator of the ;affected source shall certify
that all control techniques and processes have not been
modified subsequent to the testing upon which the data used
to establish the operating parameter ranges were obtained.
(iii) The owner or operator of an affected source may
establish expanded or replacement operating ranges for the
monitoring parameter values listed in paragraphs (a)(2)
through (a)(5) of this section and established in
paragraphs (b) (2) (i) or (ii) of this section during
subsequent performance tests using the test methods in
§ 63.865.
(3) An initial performance test is not required: to be
conducted in order to determine compliance with the emission
limitations of § 63.862(c)(l) if the affected source :
includes an NDCE recovery furnace equipped with a dry ESP
system. '•
(4) After the Administrator has approved the PM: or PM
HAP limits for each kraft or', soda recovery furnace, smelt
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200
dissolving tank, and lime kiln, the owner or operator
complying with an overall PM or overall PM HAP emission
limit established in § 63.862(a)(1)(ii) shall demonstrate
compliance with.the PM HAP standard by demonstrating
compliance with the approved PM or PM HAP emission limits
for each affected kra-ft or soda recovery furnace, smelt
dissolving tank, and lime kiln, using the test methods and
procedures in § 63.865(b).
(c) On-going compliance provisions.
(1) Following the compliance date, owners or operators
of all affected sources are required to implement corrective
action, as specified in the startup, shutdown, and
malfunction plan prepared under § 63.866(a) of this
subpart if the following monitoring exceedances occur:
(i) For a new or existing kraft recovery furnace or
lime kiln equipped with an ESP, when 10 consecutive 6-minute
averages result in a measurement greater than 20-percent
opacity; . . .
(ii) For a new or existing smelt dissolving tank, lime
kiln, or sulfite combustion unit equipped with a wet
scrubber, when any 3-hour average parameter value is outside
-------
the range of values established in paragraph (b)(2) of this
section. » •
(iii) For a new or existing semichemical combustion
unit equipped with an RTO, when any 1-hour average !
;
temperature falls below the temperature established in
paragraph (b) (2) of this section; '-
(iv) For an affected source equipped with an
alternative emission control>system approved by the \
[
Administrator, when any 3-hour average value is outside the
range of parameter values established in paragraph (b)(2) of
this section; and j
i •
(v) For an -affected source that is monitoring '
alternative operating parameters established in i
i
paragraph (a)(4) of this section, when any 3-hour avetage
value is outside the range of parameter values established
in paragraph (b)(2) of this section.
(2) Following the compliance date, owners or operators
j
of .all affected sources are in violation of the standards of
§ 63.862 if the following monitoring exceedances occur:
i !
I
(i) For an existing kraft or soda recovery furnace
equipped with an ESP, when opacity is greater than '
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202
35 percent for 6 percent or more of the time within any 6-
month reporting period;
(ii) -For a new kraft or soda recovery furnace or a new
or existing lime kiln equipped'with an ESP, when opacity is
greater than 20 percent for 6 percent or more of the time
within any 6-month reporting period;
(iii) For a new or existing smelt dissolving tank,
lime kiln, or sulfite combustion unit equipped with a wet
scrubber, when six or more 3-hour average parameter values
within any 6-month reporting period are outside the range of
values established in paragraph (b)(2) of this section;
(iv) For a new or existing semichemical combustion
unit equipped with an RTO, when any 3-hour average
temperature falls below the temperature established in
paragraph (b)(2) of this section;
(v) For an affected source equipped with an
alternative air pollution control system approved by the
Administrator, when six or more 3-hour average values within
any 6-month reporting period are outside the range of
parameter values established in paragraph (b)(2) of this
section; and
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1203
(vi) For an affected source that is monitoring \
alternative operating parameters established in
paragraph (a) (4) of this section, when six or more• 3-hour-
average values within any 6-month reporting period are
outside the range of parameter values established in
paragraph (b)(2) of this section. :
(3) For purposes of determining the number of
nonopacity monitoring exceedances, no more than one
exceedance shall be attributed in any given 24-hour period.
§ 63.865 Performance test requirements and test methods.
(a) The owner or operator of an affected source
seeking to comply with a PM or PM HAP emission limit under
§ 63.862(a)(1)(ii)(A) or (B) shall use the following >
procedures: ! ;
(1) Determine either the overall PM limit or overall
PM.HAP limit for the mill. ; \
(i) The overall PM limit for the mill shall be
'
determined as follows: ' ;
ELpM = [(CrefjRF) (QRFeot) + (Cref,LK) (QlKtot)] (Fl) / (BLSCOC) + ERlref,SDT
1 . Eq. (1)
where: ;
ELPM = overall PM emission limit for all \
existing affected sources at the kraft or
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204
soda pulp mill, kg/Mg (Ib/ton) of black
liquor solids fired.
Qref.RF = Deference concentration of 0.10 g/dscm
(0.044 gr/dscf) corrected to 8 percent
oxygen for. existing kraft or soda
recovery furnaces.
Qaptot = sum °f tne average gas flow rates
measured during the performance test from
all existing recovery furnaces at the
kraft or soda pulp mill, dry standard
cubic meters per minute (dscm/min) (dry
standard cubic feet per minute
[dscf/min]).
Cref.LK = reference concentration of 0.15 g/dscm
(0.067 gr/dscf) corrected to 10 percent
oxygen for existing kraft or soda lime
kilns.
Qi,Ktot = sum of the average gas flow rates
measured during the performance test from
all existing lime kilns at the kraft or
soda pulp mill, dscm/min (dscf/min).
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205
Fl = conversion factor, 1.44 minutes* !
kilogram/day*gram (min»kg/d»g) i
(0.206 minutes«pound/day«grain .
[min»lb/d»gr]).
BLStot = sum of the average black liquor solids .
firing rates of all existing recovery
furnaces at the kraft or soda pulp 'mill
measured during the performance test,
megagrams per day (Mg/d) (tons per 'day
[tons/d] ) of black liquor solids fired.
ERlref/SDT = reference emission rate of 0.10 kg/Mg
(0.20 Ib/ton) of black liquor solids
fired for existing kraft or soda smelt
dissolving!tanks; or
(ii) The overall PM HAP limit for the mill shall be
determined as follows: :
'
KLPMHAP = ERref/RF + (ERref/LK) (CaOtot/BLStoc) + ER2ref/SDT
' Eq. (2)
* I |
where: ' ;
ELPMHAP = overall PM HAP emission limit for all
existing affected sources at the kraft or
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206
soda pulp mill, kg/Mg (Ib/ton) of black
liquor solids fired.
ERref/RF = reference emission rate of l.OOE-03 kg/Mg
(2.01E-03 Ib/ton) of black liquor solids
fired for existing kraft or soda recovery
furnaces.
ERref/LK = reference emission rate of 6.33E-03 kg/Mg
(1.27E-02 Ib/ton) of CaO produced for
existing kraft or soda lime kilns.
CaOtoc = sum of • the average lime production rates
for all existing lime kilns at the kraft
or soda pulp mill measured as CaO during
the performance test, Mg CaO/d (ton
CaO/d).
BLStoc = .sum of average black liquor solids firing
rates of all existing recovery furnaces at
the kraft or soda pulp mill measured
during the performance test, Mg/d (ton/d)
of black liquor solids fired.
ER2ref/SDT = reference emission rate of 6.20E-05 fcg/Mg
(1.24E-04 Ib/ton) of black liquor solids
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;207
fired for existing kraft or soda smelt
dissolving !tanks.
(2) Establish a preliminary emission limit for each
kraft or soda recovery furnace (CEL,RF) , smelt dissolving tank
(CEX,,SDT) , and lime kiln (CEL/LK) ; and, using these emission
limits, determine the overall PM or overall PM HAP emission
rate for the mill using the procedures in § 63.865(a)(2)(i)
through (v) , such that the overall PM or overall PM HAP
emission rate calculated in § 63.865(a)(2)(v) is less than
or equal to the overall PM or overall PM HAP emission limit
determined in § 63.865(a)(1), as appropriate. ;
(i) The following equation shall be used to determine
the PM or PM HAP emission rate from each affected recovery
furnace: ;
ERRF = (Fl) (CEL;RF) (QRF)/(BLS) Eq. (3)
|
where: j • :
ERRF = emission rate from each recovery furnace,, kg/Mg
(Ib/ton) of black liquor solids. '
r
Fl = conversion factor, 1.44 min«kg/d»g ;
: (0.206 min»lb/d«gr).
CEL/RF = preliminary PM or PM HAP emission limit
proposed by owner or operator for the recovery
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208
furnace, g/dscm (gr/dscf) corrected to
8 percent oxygen.
QRF = average volumetric gas flow rate from the
recovery furnace measured during the
performance test, dscm/min (dscf/min).
BLS = average black liquor solids firing rate of the
recovery furnace measured during the
performance test, Mg/d (ton/d) of black liquor
solids.
(ii) . The following equation shall be used to determine
the PM or PM HAP emission rate from each affected smelt
dissolving tank:
ERSDT = (Fl) (CEL/SDT) (QSDT)/(BLS) ' Eq. '(4)
where:
ERSDT = emission rate from each SDT, kg/Mg (Ib/ton) of
black liquor solids fired.
Fl = conversion factor, 1.44 min«kg/d*g •
(0.206 min»lb/d»gr).
CEL,SDT = preliminary PM or PM HAP emission limit proposed
by owner or operator for the smelt dissolving
tank, g/dscm (gr/dscf) corrected to 8 percent
oxygen.
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209
r
QSDT = average volumetric • gas flow rate from the smelt
dissolving tank measured during the performance
test, dscm/min (dscf/min).
i
BLS = average black liquor solids firing rate of; the
associated recovery furnace measured during the
performance test, ;'Mg/d (ton/d) of black liquor
solids fired. If more than one SDT is used to
dissolve the smelt from a given recovery
furnace, then the iblack liquor solids firing
rate of the furnace shall be proportioned
according to the size.of the SDT's.
(iii) The following equation shall be used to ;
determine the PM or PM HAP emission rate from each affected
lime kiln: ;
ERLK = (Fl) (CEL,LK) (QLK) (CaOtot/BLStot) / (CaOLK) ;
I Eq. (5)
where: i ;
ERLK = emission rate .frqm each lime kiln, kg/Mg
(Ib/ton) of black liquor solids.
Fl = conversion factor, 1.44 min«kg/d»g '
L
'
: ' (0.206 min»lb/d»gr). ;
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210
CEL,LK = preliminary PM or PM HAP emission limit
proposed by owner or operator for the lime
kiln, g/dscm (gr/dscf) corrected to 10 percent
oxygen.
QLK = average volumetric gas flow rate from the lime
kiln measured during the performance
test, dscm/min (dscf/min).
CaOLK = lime production rate of the lime kiln, measured
as CaO during the performance test, Mg/d
(ton/d) of CaO.
CaOt-ot = sum of the average lime production rates for
all existing lime kilns at the mill measured as
CaO during the performance test, Mg/d (ton/d).
BLStot = sum of the average black liquor solids firing •
rates of all recovery furnaces at the mill
measured during the performance test, Mg/d
(ton/d) of black liquor solids.
(iv) If more than one similar process unit is operated
at the kraft or soda pulp mill, the following equation shall
be used to calculate the overall PM or overall PM HAP
emission rate- from all similar process units at the mill and
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•'
HAP emission rate for the mill: i
I
ERputot = ERPU1 (PRPU1/PRtotj + . + (ERPUi) (PRPUi/PRtot)
1 Eq. (6)
where: ; | i
ERPUtot = overall PM or overall PM HAP emission rate ]
from all similar process units, kg/Mg (Ib/ton)
! v
s - i
of black liquo± solids fired. .
ERP01 = PM or PM HAP emission rate from process; unit
No. 1, kg/Mg (Ib/ton) of black liquor solids
i ;
fired, calculated using equation (3), (4), or
(5) . i
PRPU1 = black liquor solids firing rate in Mg/d
(ton/d.) for process unit No. 1, if process
unit is a recovery furnace or SDT. The CaO
production rate in Mg/d (ton/d) for process
i •
unit No. 1, if :process unit is a lime kiln.
I '
i |
PRtot - total black liquor solids firing rate in Mg/d
(ton/d) for all recovery furnaces at the kraft
i
or soda pulp mill if the similar process units
are recovery furnaces or SDT's, or the total
1
CaO production I rate in Mg/d (ton/d) for all
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212
lime kilns at the mill if the similar process
units are lime kilns.
ERPUi = PM or PM HAP emission rate from process unit
No. i, kg/Mg (Ib/ton) of black liquor solids
fired.
PRptii = black liquor solids firing rate in Mg/d
(ton/d) for process unit No. i, if process
unit is a recovery furnace or SDT. The CaO
production rate in Mg/d (ton/d) for process
unit No. i, if process unit is a lime kiln.
i = number of similar process units located at the
kraft or soda pulp mill.
(v) The following equation shall be used to calculate
the overall PM or overall PM HAP emission rate at the mill:
ER-tot = ERRFtot + ERSDTtot + ERLKtot . Eq. (7)
where:
ERtot = overall PM or overall PM HAP emission rate
for the mill, kg/Mg (Ib/ton) of black
liquor solids fired.
ERRFtot = PM or PM HAP emission rate from all kraft
or soda recovery furnaces, calculated using
equation (3) or (6), where
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213 ;
applicable, kg/Mg (Ib/ton) of black liquor
solids fired:. '-
ERSDTtot = PM or PM HAP! emission rate from all smelt
[
dissolving tanks, calculated using equation
(4) or (6), where applicable, kg/Mg ;
I
(Ib/ton) of black liquor solids fired.
ERLKtot = PM or PM HAP' emission rate from all lime
kilns, calculated using equation (5) ,or
(6), where applicable, kg/Mg (Ib/ton) of
black liquor1 solids fired.
(
(3) For purposes of determining the volumetric ;gas
flow rate used in this section for each kraft or soda
recovery furnace, smelt dissblving tank, and lime kiln,
Methods 1 through 4 of appendix A, part 60 of this chapter
l
shall be used. ;.
(4) Process data measured during the performance test
shall be used to determine the black liquor solids firing
rate on a dry basis and the CaO production rate. :
.
(b) The owner or operator seeking to determine \
compliance with § 63.862(a) shall use the following :
procedures: j
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(1) For purposes of determining the concentration of
PM emitted from each kraft or soda recovery furnace, sulfite
combustion unit, smelt dissolving tank or .lime kiln,-
Method 5 or 29 in appendix A of part 60 of this chapter
shall be used, except that. Method 17 in appendix A of part
60 may be used in lieu of Method 5 or Method 29 if a
constant value of 0..009 g/dscm (0.004 gr/dscf) is added to
the results of Method 17, and the stack temperature is no
greater than 205°C (400°F). The sampling time and sample
volume for each run shall be at least 60 minutes and
0.90 dscm (31.8 dscf). Water shall be used as the cleanup
solvent instead of acetone in the sample recovery procedure.
(i) For sources complying' with § 63.862(a) (1) or (2),
the PM concentration shall be corrected to the appropriate
oxygen concentration using the following equation:
Ccorr = Cmeas X (21-X/21-Y) Eq. (8)
where:
=(the measured concentration corrected for
oxygen, g/dscm (gr/dscf).
= the measured concentration uncorrected for
oxygen, g/dscm (gr/dscf).
-corr
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215
' ' i
X = the corrected volumetric oxygen concentration
(8 percent for^kraft or soda recovery furnaces
and sulfite combustion units and 10 percent
for lime kilns). ;
i
Y = the measured average volumetric oxygen ;
concentration.,
The integrated sampling and 'analysis procedure of Method 3B
shall be used to determine the oxygen concentration.'. The
gas sample shall be taken at the same time and at the same
j
traverse points as the particulate sample.
(2) For purposes of determining the PM HAP emitted
from each kraft or soda recovery furnace, smelt dissolving
tank, or lime kiln, Method 29 in appendix A of part 60 of
this chapter shall be used. Method 101A in appendix B of
part 61 may be used as an alternative to Method 29 for
determining mercury emissions. When determining the PM HAP
emission rate, all nondetect' data, as defined in § 63.861,
shall be treated as one-half of the method detection limit.
The sampling time and sample: volume for each run shall be at
i
least 60 minutes and 1.27 dscm (45 dscf).
(i) The following equation shall be used to determine
the PM HAP emission rate from each recovery furnace:
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216
ERRF.PMHAP = (PMHAPmeas)/(BLS) Eq. (9)
where :
ERRF.PMHap = PM HAP emission rate from each recovery
furnace, kg/Mg (Ib/ton) of black liquor
solids fired.
PMHAPraeas = measured PM HAP mass emission rate, kg/h-r
BLS = average black liquor. solids firing rate,
Mg/hr (ton/hr) ; determined using process
data measured during the performance test .
(ii) The following equation shall be used to determine
the PM HAP emission rate from each smelt dissolving tank:
ERSDT.PMHAP = (PMHAPmeas)/(BLS) Eq. (10)
where :
ER-SDT-PMHAP = PM HAP emission rate from each smelt
dissolving tank, kg/Mg (Ib/tpn) of black
liquor solids fired.
PMHAPmeas = measured PM HAP mass emission rate, kg/hr
(lb/hr) .
BLS = average black liquor solids firing rate of
the associated recovery furnace, Mg/hr
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217
(ton/hr) ; determined using process data
measured during the performance test.
(iii) The following equation shall be used to
determine the PM HAP emission rate from each lime kiln:
ERLK.PMHAP = (PMHAPmeas)/(CaO) Eq. (11)
where: :
i
HRLK-PMHAP = PM HAP emission rate from each lime I
kiln, kg/Mg (Ib/ton) of black liquor .
solids fired.
PMHAPmeas = measured PM HAP mass emission rate, kg/hr
(Ib/hr). ' ;
CaO = average lime production rate, Mg/hr
(ton/hr); measured as CaO and determined
using process data measured during the
i
performance, test.
(c) The owner or operator seeking to determine
compliance with the total gaseous organic HAP standard in
§ 63.862 (c) (1) without using!an NDCE recovery furnace
equipped with a dry ESP system shall use Method 308 in
i
Appendix A of part 63 of this chapter. The sampling ;time
and sample volume for each run shall be at least 60 minutes
and 0.014 dscm (0.50 dscf), respectively. ;
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218
(1) The following equation shall be used to determine
the emission rate from any new NDCE recovery furnace:
ERjrocE = (MRraeas) / (BLS) . Eq. (12)
where: ' * . •
= methanol emission rate from the NDCE
recovery furnace, kg/Mg (Ib/ton) of black
liquor solids fired.
= measured methanol mass emission rate from
the NDCE recovery furnace, kg/hr (Ib/hr).
BLS = average black liquor solids firing rate of
the NDCE recovery furnace, Mg/hr (ton/hr);
determined using process data measured
during the performance test.
(2) The following equation shall be used to determine
the emission rate from any new DCE recovery furnace system:
ERDCE = [ (MRraeas,RF) /BLSRF] + [ (MRmeas/BLO) /BLSBLO]
Eq. (13)
where:
ERDCE = methanol emission rate from each DCE
recovery furnace system, kg/Mg (Ib/ton) of
black liquor solids fired.
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219 '•
MRmeaSfRF = average measured methanol mass emission
rate from each DCE recovery furnace, kg/hr
(Ib/hr). :
i f
MRraeas,BLo = average measured methanol mass emission
rate from the black liquor oxidation
system, kg/hr (Ib/hr).
BLSRF = average black liquor solids firing rate
for each DGE recovery furnace, Mg/hr
(ton/hr); determined using process data
measured during the performance test.
BLSBLO = the average mass rate of black liquor
solids treated in the black liquor
oxidation system, Mg/hr (ton/hr);
determined 'using process data measured '
during the performance test.
(d) The owner or operator seeking to determine ;
i
compliance with the total gaseous organic HAP standards in
§ 63.862(c)(2), (standards for semichemical combustion
units) shall use Method 25A in appendix A of part 60 of this
chapter. The sampling time shall be at least 60 minutes.
(1) The following equation shall be used to determine
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220
the emission rate from any new or existing semichemical
combustion unit:
ERSCCU = (THCmeas)/(BLS) ' Eq. (14)
where:
ERsccu = THC emission rate from each semichemical
combustion unit, kg/Mg (Ib/ton) of black
liquor solids fired.
THCmeas = measured THC mass emission rate, kg/hr
(Ib/hr).
BLS = average black liquor solids firing rate,
Mg/hr (ton/hr); determined using process
data measured during the performance test.
(2) If the owner or operator of the semichemical
combustion unit has selected the percentage reduction
standards for THC, under § 63.862(c)(2)(ii) of this subpart,
the percentage reduction in THC emissions (%RTHc) i-s computed
using the following formula, provided that E± and E0 are
measured simultaneously:
E - E
(%R ) =
THC
X 100 Eg. (15)
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221 ;
where: j ;
%RTHC = percentage reduction of total hydrocarbons
emissions achieved.
Ei = measured THC mass emission rate at the THC
control device inlet, kg/hr (Ib/hr). \
E0 = measured THC mass emission rate at the THC
i
control device outlet, kg/hr (Ib/hr). :
i • . •
(e) The owner or operator seeking to comply with the
continuous parameter monitoring requirements of \
§ 63.864(b)(2) shall continuously monitor each parameter and
determine the arithmetic average value of each parameter
during each 3-run performance test. Multiple 3-run '
performance tests may be conducted to establish a range of
parameter values.
(f) The owner or operatlor of an affected source;
seeking to demonstrate compliance with the standards in
§ 63.862 using a central technique other than those listed
in ;§ 63.864 (a) (1) through (a)j(3) shall provide to the
•
Administrator a monitoring pian that includes a description
of the control device, test results verifying the
performance of the control device,.the appropriate operating
parameters that will be monitored, and the frequency of
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222
measuring and recording to establish continuous compliance
with the standards. The monitoring plan is subject to the
Administrator's approval. The owner or operator of the
affected source shall install, calibrate, operate, and
maintain the monitor(s) in accordance with the monitoring
plan approved by the Administrator. The owner or operator
shall include in the information submitted to the
Administrator proposed performance specifications and
quality assurance procedures for their monitors. The
Administrator may request further information and shall
approve acceptable test methods and procedures.
§ 63.866 Recordkeeping requirements.
(a) Startup, shutdown, and malfunction plan. The
owner or operator shall develop and implement a written plan
as described in § 63.6(e)(3) of this part that contains
specific procedures to be followed for operating the source
and maintaining the source during periods of startup,
shutdown, and malfunction and a program of corrective action
for malfunctioning process and control systems used to
comply with the standard. In addition to the information
required in § 63.6(e) of this part, the plan shall include
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: |223 ;
the requirements in paragraphs (a)(1) and (a)(2) of this
,
section. : ,
(1) The startup, shutdown, and malfunction plan shall
i
include procedures for responding to any process parameter
level that is inconsistent with the level(s) established
under § 63.864(b)(2), including:
(i) Procedures to determine and record the cause of an
J!
operating parameter exceedance and the time the exceedance
began and ended; and . : '
i
(ii) Corrective actions to be taken in the event of an
operating parameter exceedance, including procedures for
recording the actions taken to correct the exceedance:.
(2) The startup, shutdown, and malfunction plan also
•
shall include: j
(i) A maintenance schedule for each control technique
that is consistent with, but |not limited to, the
manufacturer's instructions and recommendations for routine
and long-term maintenance; and
(ii) An inspection schedule for each continuous
monitoring system required under §63.864 to ensure, at least
once in each 24-hour period, that each continuous monitoring
system is properly functioning.
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224
(b) The owner or operator of an affected source shall
maintain records of any occurrence when corrective action is
required under § 63.864 (c) (1), and when a violation is noted
under § 63.864(c)(2).
(c) In addition to the general records required by
§ 63.10(b)(2) of this part, the owner or operator shall
maintain,records of the following information:
(1) Records of black liquor solids firing rates in
units of megagrams/day or tons/day for all recovery furnaces
and semichemical combustion units;
(2) Records of CaO production rates 'in units of
megagrams/day or tons/day for all lime kilns;
(3) Records of parameter monitoring data required
under § 63.864, including any period when the operating
parameter levels were inconsistent with the levels
established during the initial performance test, with a
brief explanation of the cause of the deviation and the
corrective action taken;
(4) Records and documentation of supporting
calculations for compliance determinations made under
§§ 63.865(a) through (e);
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225
(5) Records of monitoring parameter ranges established
! '
for each affected source; ;
(6) Records certifying that an NDCE recovery furnace
equipped with a dry ESP system is used to comply with the
total gaseous organic HAP standard in § 63.862(c)(1).
§ 63.867 Reporting requirements.
(a) Notifications. The owner or operator of any
affected source shall submit' the applicable notifications
from subpart A of this part,' as specified in Table 1;of this
subpart. ' \
(b) Additional reporting requirements for PM HAP
standards. i '
(1) Any owner or operator of a group of affected
i
sources at a mill complying with the PM HAP standards in
§ 63.862(a)(1)(ii) shall submit the PM or PM HAP emission
limits determined in § 63.865 (a) for each affected kraft or
soda recovery furnace, smelt; dissolving tank, and lime kiln
to the Administrator for approval. The emission limits
shall be submitted as part of the notification of compliance
status required under subpart A of this part. ;
(2) Any owner or operator of an affected source
I
complying with the -PM or PM HAP standards in
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226
§ 63.862(a)(1)(ii) shall submit the 'calculations and
supporting documentation used in § 63.865 (a) (1) and (2) to
the Administrator as part of the notification .of compliance
status required under subpart A of this part.
(3) After the Administrator has approved the emission
limits for any affected source, the owner or operator of an
affected source must notify the Administrator before any of
the following actions are taken:
(i) The air pollution control system for any affected
source is modified or replaced;
(ii) Any kraft or soda recovery furnace, smelt
dissolving tank, or lime kiln at a kraft or soda pulp mill
complying with the PM or PM HAP standards in
§ 63.862 (a) (1) (ii) is shut down for more than '60 consecutive
days ;
(iii) A continuous monitoring parameter or the value
or range of values of a continuous monitoring parameter for
any affected source is changed; or
(iv) The black liquor solids firing rate for any kraft
or soda recovery furnace during any 24-hour averaging period
is increased by more than 10 percent above the level
measured during the most recent performance test.
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;- 227 '
(4) An owner or operator of a group of affected
sources at a mill complying with the PM or PM HAP standards
I
in § 63.862(a)(1)(ii) and seeking to perform the actions in
paragraphs (b) (3) (i) or (ii)' of this section shall
recalculate the overall PM or overall PM HAP emission limit
for the group of affected sources and resubmit the
documentation required in paragraph (b) (2) of this section
to the Administrator. All modified PM and PM HAP emission
i
limits are subject to approval by the Administrator.:
(c) Excess emissions report. The owner or operator
shall report quarterly if measured parameters meet any of
the conditions specified in !§ 63.864 (c) (1) or (2) . This
report shall contain the information specified in § 63.10(c)
[
of this part as well as the number and duration of
i
occurrences when the source met or exceeded the conditions
in § 63.864 (c) (l)and the number and duration of occurrences
_
when the source met or exceeded the conditions in
§ 63.864(c)(2). !
(1) When no exceedances of parameters have occurred,
the owner or operator shall submit a semiannual report
stating that no excess emissions occurred during the '.
reporting period. j
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228
(2) The owner or operator of an affected source
subject to the requirements of this subpart and subpart S of
this part may combine excess emission and/or summary reports
i
for the mill.
§ 63.868 Delegation of authority.
(a) In delegating implementation and enforcement
authority to a State under section 112(d) of the Act, the
authorities contained in paragraph (b) of this section shall
be retained by the Administrator and not transferred to a
State.
(b) Authorities which will not be delegated to States:
No authorities are retained by the Administrator.
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